In response to legal actions taken by environmental groups, Wyoming Wildlife Services (WY-WS) was responsible for completing an environmental assessment of their predator management actions – known as predator damage management (PDM). Wyoming Wildlife Services had four alternatives they put forth and collected public comments for 30 days.
Predictably, they chose the alternative that kept their operations the same citing a lack of any environmental impacts as a result of PDM actions. Specifically, they stated, “APHIS-WS provides federal professional leadership and expertise to…resolve wildlife conflicts to help create a balance that allows people and wildlife to coexist. Our analyses in Chapter 3 of the EA show that Alternatives 1, 2, 3, and 4 will not result in any significant impacts on the environment.” The lack of determining there would be no/few environmental impacts precluded the agency from performing a more in-depth environmental impact statement (EIS). We did a thorough evaluation of the environmental assessment to see what justifications were used and arguments presented to keep operations the same. Read on to see what we found.
The Wildlife Services (WS)-Wyoming Environmental Assessment (EA) covers the predator damage management (PDM) practices used by the organization and evaluates the different options for continued work in the state. WS goal for PDM “is to manage predator damage, threats of damage, and risks to human/pet health and safety by responding to all requests for assistance, including technical assistance and/or direct operational assistance, regardless of the source of the request, private or public.” PDM is conducted to alleviate the damage caused by predators to private or public property and safety. WS-Wyoming is contracted by federal, state, and private groups to do PDM related to several mammalian predators. WS is required to be compliant with the National Environmental Policy Act (NEPA) as a federally funded agency. WS-Wyoming uses lethal methods as they believe most groups have already attempted non-lethal techniques and are a reaching out for lethal assistance and expertise. Through WS-Wyoming process, they are supposed to pursue non-lethal options as often as possible but are not required to do so before pursuing lethal methods.
WS-Wyoming evaluated whether proposed actions and alternatives presented in the EA resulted in significant impacts in two ways: “(1) the severity of magnitude of the impact, and (2) the context of the impact” in compliance with the Center of Environmental Quality (CEQ) regulations. WS-Wyoming evaluated significant impacts using the baseline of an environment “already heavily influenced by human actions including WS-Wyoming PDM which have been conducted in Wyoming for more than a century, and PDM conducted by other federal, state, and local agencies, as well as individuals and other entities.” The need for PDM by WS-Wyoming comes from $936,466 of damage loss reported to the agency with $852,704 of the losses from livestock. Coyotes make up 71% of reported damage. Mountain lions and grizzly bears make up ~7% of reported damage each with the remaining 16% of damage coming from 12 other species. WS-Wyoming demonstrates areas with PDM have lower losses, but that is not true in all places, including in Wyoming.
WS-Wyoming proposed four alternatives that are evaluated through six issues. Alternatives are as follows: Alternative 1 No Action/Proposed Action, Continue the Current Federal Integrated Predator Damage Management Program; Alternative 2 Lethal PDM Methods Used by WS-Wyoming Only for Corrective Control; Alternative 3 WS-Wyoming Provides Technical Assistance Only; Alternative 4 No WS-Wyoming PDM Program. Issues are: A. Impact on Populations of Target Species; B. Impacts on Populations of Non-target species; C. Impacts on Ecosystem Function; D. Impacts on Human and Pet Health and Safety; E. Impacts on Use of Public Lands; F. Impacts on Other Sociocultural Issues.
Main actions that would be taken by WS-Wyoming under alternative 1 related to the impact on populations of target species looked at what was a sustainable number of kills for a species that would not affect the statewide population. Direct impacts by WS-Wyoming would be killing less than 15,000 coyotes and removals of 400 burrows/dens in a year, about 17% of the population. They believe this would locally impact coyote populations for a few years but would have no long term affects. This is due to research by Connolly and Longhurst (1975) and Connolly (1995) which claim statewide coyote populations will not be impacted on a long term by killing less than 60% of the population a year. High numbers of coyote kills are justified due to coyotes making up 71% of property damage suggesting more management is required. The only indirect impact presented for this alternative is a younger age structure in local coyote populations. Statewide impacts are viewed as negligible. Hunters are believed to kill up to an additional 2,000 coyotes each year in addition to kills by WS-Wyoming. This would bring the amount of coyote population killed up to ~19%. Because this is below the 60% “take” that is viewed as moving toward an unstainable population, the cumulative impact on statewide coyote populations by WS-Wyoming under alternative 1 is viewed as not significant.
Under alternative 2 fewer coyotes will be killed as WS-Wyoming can only respond to conflict after it has taken place, not before. Preventative control involves killing a large number of coyotes in areas of historical coyote damage. The killing of coyotes by private individuals or wildlife control companies would potentially increase, but due to lack of experience less kill would be expected. Much of the preventative coyote control is also done by aerial PDM, so WS-Wyoming would also spend less time and money doing aerial PDM under this alternative. Cumulative impact on statewide coyote populations under alternative 2 are considered not significant and less significant than alternative 1.
Under alternative 3 and 4, WS-Wyoming would have no impact on coyote populations as they would only conduct technical assistance or not be involved at all. It is believed that private groups or state agencies would take over PDM and that the level of kill could increase. Speculation about the effects of WS-Wyoming not conducting PDM follows related to non-target killing and intolerance of wildlife by individuals. Ultimately the impact of killing on coyote populations is viewed as decreasing although still no significant cumulative impact is found as it was not under alternative 1 where the greatest impact would take place. Other than the red fox, all other predator species largely affected by WS-Wyoming actions under alternative 1 are under jurisdiction of WGFD who is then responsible for maintaining and managing a healthy population.
WS-Wyoming reported 228 total non-target animals killed between FY14-18, 130 of which were other mammalian predator species. Most non-predator kills are viewed as inconsequential because hunters kill a significantly larger amount of each of the species than WS-Wyoming. They believe the only three threatened and endangered species that may be negatively affected by PDM are: Canada Lynx, Grizzly Bear, and North American Wolverine. USFWS believes WS-Wyoming PDM activities could result in 5 non-target captures of grizzly bears a year and no more than 2 mortalities which they believe will not result in significant harm to the population.
Environmental and Wildlife safety concerns revolve around the use of lead ammunition by WS-Wyoming. Support for continued use is “Lead-free ammunition is often more expensive than equivalent lead ammunition. Costs may sometimes be secondary to overriding environmental, legal, public safety, animal welfare, or other concerns. But it is still an issue. Cooperators pay a substantial portion of operation program costs and may be unwilling to pay the additional ammunition costs where it is legal to use lead ammunition.” WS-Wyoming believes there is “a potential to adversely impact individual non-target animals, particularly animals which scavenge carcasses,” but the overall use of lead ammunition will have no adverse impact on populations.
Aerial PDM is not expected to have an adverse impact on wildlife because they only fly for a few days a year on any given plot of land which is significantly less than the possible use by the Air National Guard. The Air National Guard (1997) has also concluded the training exercises they run do not adversely impact wildlife which is why WS-Wyoming does not believe they will adversely affect wildlife through their use. WS-Wyoming found “some species will frequently, or at least occasionally, show what appear to be adverse responses to even minor overflight occurrences…the greatest potential for impacts would be expected when overflights are frequent and over many days,” but there will be negligible or no impact on non-target wildlife populations.
For non-target kills, lead ammunition use, and aerial PDM, the greatest impact will come from alternative 1, less from alternative 2, and only non WS-Wyoming impact from alternatives 3 and 4.
Due to analyses evaluating how many kills will not endanger a wildlife population undertaken during previously, only temporary impacts on ecosystem function are anticipated by WS-Wyoming. The largest anticipated impacts would be on the red fox population as it will fluctuate depending on the number of nearby coyotes who are the primary target of most PDM activities. In addition, the quick recovery found in coyote populations from PDM leads to no long-term ecosystem impacts if PDM does not result in killing off more than 60% of the population for multiple years. An additional short-term result of coyote PDM is local increases in small mammal prey species populations until coyotes return to the area.
The main health and safety issues identified by WS-Wyoming is aerial PDM accidents, lead contamination from the use of lead ammunition, and use of M-44s. Lead contamination was viewed as not an issue because “Lead did not appear to ‘transport’ readily in surface water when soils were neutral or slightly alkaline, but lead did transport more readily under slightly acidic conditions” (Stansley et al. 1992). The age of the sources used to evaluate lead contamination from lead bullets is concerning as there have certainly been more recent research done on the topic. Use of M-44s on landscapes is viewed to not have a significant impact on human or pet safety due to signage in area of use and “limited likelihood of any human or pet exposure.” WS-Wyoming does not report the injury or encounters between any M-44s and pets. WS-Wyoming views there to be negligible impacts on health and safety due to their proposed actions.
Based off recommendations produced by American Veterinary Medical Association (2007), WS-Wyoming justifies the use of inhumane practices of killing wildlife, such as use of M44s and shotguns, because of the challenges facing them in doing it in a humane way. Because the work being done is for the overall benefit of society, WS-Wyoming is permitted to just shoot animals rather than find more humane ways of euthanasia although this permission does not absolve them from taking the life in an inhumane way.
Across all these issues, alternative 1 would have the most significant impact followed by alternative 2 with alternatives 3 and 4 only having impact from hunting and PDM conducted by groups other than WS-Wyoming. WS-Wyoming shows a great deal of bias whenever discussing alternatives 3 and 4 suggesting groups other than WS-Wyoming would act in a less humane and more inefficient way because of the lack of expertise and rules they will have. They regularly propose the idea of their organization being the best for the job and without their presence the work will not get done in as good of a way proposing that landowners will respond in a more extreme way.
Wyoming Wildlife Services Final Environmental Assessment Predator Damage and Conflict Management in Wyoming. 2020. Final EA
Air National Guard 1997. Final Environmental Impact Statement for the Colorado Airspace Initiative: Impact analyses. United States Department of Defense. Andrews Air Force Base, Maryland, USA.
American Veterinary Medical Association. 2007. AMVA guidelines on euthanasia (formerly report the AVMA panel of euthanasia) June 2007.
Connolly, G. E., and W.M. Longhurst. 1975. The effects of control on coyote populations. University of California – Division of Agricultural Science, Davis, California, USA.
Connolly, G.E. 1975. The effects of control on coyote populations: Another look. Pages 21-29 in D. Rollings, C. Richardson, T. Blankenship, K. Canon, and S. Henke (Incomplete citation in EA)
Stansley, W., L. Widjeskog, and D. E. Roscoe. 1992. Lead contamination and mobility in surface water at trap and skeet ranges. Bulletin of Environmental Contamination and Toxicology 49(5):640-647