PREDATOR CONSERVATION ALLIANCE
AMERICAN LANDS ALLIANCE
BIODIVERSITY LEGAL FOUNDATION
CLEARWATER BIODIVERSITY PROJECT
COLORADO WILD
FRIENDS OF THE CLEARWATER
FRIENDS OF THE WEST
GREATER YELLOWSTONE COALITION
HELLS CANYON PRESERVATION COUNCIL
IDAHO CONSERVATION LEAGUE
JACKSON HOLE CONSERVATION ALLIANCE
THE LANDS COUNCIL
MONTANA AUDUBON COUNCIL
MONTANA WILDERNESS ASSOCIATION
NORTHWEST ECOSYSTEM ALLIANCE
RESTORE: THE NORTH WOODS
SINAPU
SWAN VIEW COALITION
WESTERN LAKES WILDLIFE CENTER
THE WILDERNESS SOCIETY
WILDLIFE DAMAGE REVIEW
WYOMING OUTDOOR COUNCIL
September 24, 1999
Mr. Kemper McMaster, Field Supervisor
U.S. Fish and Wildlife Service, Montana Field Office
100 N. Park Avenue, Suite 320
Helena, MT 59601
Dear Mr. McMaster:
We are writing on behalf of our respective organizations in response to the "Lynx Science Report" recently released by the U.S. Forest Service Rocky Mountain Research Station, and its implications for the decision whether to list the lynx (Lynx canadensis) for protection under the Endangered Species Act. We believe the new report provides added justification on many counts for the U.S. Fish and Wildlife Service to list the lynx for protection as an endangered species throughout its current and former range in the contiguous United States without further delay.
We begin by reviewing the five criteria for listing a species for protection under the Endangered Species Act and their relevance to lynx in the contiguous United States (Part I). We then excerpt some relevant passages from the report to support our position that the lynx meets these criteria for protection as Endangered (Part II). Thank you for your consideration.
PART I. REASONS TO PROTECT LYNX UNDER THE ENDANGERED SPECIES ACT
A. Range or Habitat Destruction or Modification Past, Present, or Future
Although the exact current range of lynx is not known, McKelvey et al. report in Chapter 8 that it has significantly decreased, from 24 states historically to confirmed presence in just six states today: Montana, Washington, Oregon, Wyoming, Maine, and Colorado (the latter due to a reintroduction project). McKelvey et al. report that lynx were found in high densities in four states historically (Montana, Washington, Minnesota, and New Hampshire), but today lynx achieve only moderate densities in parts of Montana and Washington, and exist in very low densities everywhere else. Further, the increasing fragmentation and isolation of lynx populations from each other and from larger lynx populations in Canada makes lynx survival even more tenuous than their low numbers alone would indicate.
While declines in lynx range and numbers may be due in part to natural processes, the most recent and most serious decline began in the 1960s, and it is directly attributable to human actions. The report describes the deleterious effects of traditional forestry practices on lynx habitat (Chapters 3, 4, 10, 13, 14, 15; see below Part II, B-D). These practices were implemented on national forests in earnest starting in the 1960's throughout the last productive areas of lynx habitat in the U.S. northern Rockies and Northwest, and continue in these same areas today.
B. Overuse for Commercial, Sporting, Scientific, or Educational Purposes
The report contains data that reveal a final peak in lynx trapping in the 1970's, when lynx were trapped at high numbers in their last remaining strongholds in the lower 48: Montana, Washington, and Minnesota (Chapter 8, Figs. 8.4, 8.5, 8.7). Since then, sharp declines in lynx trapping and observations in general indicates that this level of exploitation was not sustainable, and that lynx have still not recovered from this overuse. Legal trapping is no longer a conservation concern due to its dramatic decline following the 1970's, but illegal and incidental trapping are believed to be additive to other sources of mortality and may threaten lynx survival and recovery in some areas (Chapter 13; see below Part II, H).
C. Depletion Through Disease, Predation, or Grazing
Direct predation and competition in general with coyotes, mountain lions, and bobcats has not been well-documented for lynx, but the report's authors believe it is an important factor in many areas of the contiguous U.S., where marginal levels of lynx fitness and reproduction cannot keep pace with competition and mortality from other generalist predators. The report mentions that these competitors are aided by certain human activities and developments, such as when roads and trails are created into lynx habitat, and generalist predators find easier access into what was once exclusively lynx habitat (Chapters 4, 14; see below Part II, D).
D. Inadequate Laws or Regulations
Past laws and regulations failed to prevent overtrapping of lynx until it was too late, and current laws and regulations are inadequate to protect lynx habitat, the limiting factor to lynx recovery today. The report indicates that current USFS forest plans and policies have been inadequate to prevent the past and ongoing loss and fragmentation of lynx habitat, especially due to forestry practices and associated roads. Not only do these plans need to be reformed to ensure that site-specific project incorporate lynx needs, but management must be also be coordinated on a regional scale to ensure lynx populations may interchange and thus function as a metapopulation, rather than isolated fragments that are much more vulnerable to extirpation (Chapter 15 and others; see all of Part II below).
E. Other Natural or Manmade Factors Affecting Existence
Though it receives little attention in the report, there is some evidence in the northern Rockies and perhaps elsewhere that environmental conditions may be changing at the expense of lynx, with milder temperatures and decreased snowpack at mid-elevations (ca. 5000 feet) that may contain important habitat for lynx (John Weaver, pers. comm., September 1999). This decreased snowpack coupled with high densities of packed roads and trails in many areas provides increased access into lynx habitat by its competitors to the detriment of lynx.
Conclusion of Part I
For the reasons described above, human actions have directly and indirectly precipitated the alarming decline of lynx populations throughout their former range in the northern forests of the contiguous United States. Consequently, we believe the U.S. Fish and Wildlife Service has the obligation to intervene to prevent any further declines, and begin the process of restoring the lynx to its natural levels of distribution and abundance. Further evidence to support this position is excerpted from the Lynx Science Report in Part II that follows.
PART II. EXCERPTS FROM THE LYNX SCIENCE REPORT THAT SUPPORT ESA PROTECTIONS FOR LYNX
A. Lynx in the contiguous lower 48 states are imperiled, and the threats to their survival are immediate.
We know remarkably little about the current status and numbers of lynx in the contiguous United States. However, what little we know indicates that the subpopulations are not large. Until we better determine the current location and sizes of lynx subpopulations, it is unwise to assume that these populations can be reduced or further isolated without sharply increasing the risk of their individual and collective extinction. II, 14
1. Researchers with lynx field studies currently underway were able to trap few lynx and found those lynx had large home ranges, indicating that lynx population size, density, and productivity in the southern boreal forests are characteristic of the northern populations during the low phase of the snowshoe hare population cycle. This was the case even in a study area well north of the U.S./Canada border.
Preliminary telemetry data suggest that lynx in Montana and Wyoming have large home ranges; this result supports the Koehler and Aubry (1994) contention that lynx from southern lynx populations have large spatial-use areas. XI, 1
Because my study period coincided with the increase phase of a hare cycle (C. J. Krebs, personal communication), assuming geographic synchrony, my results are consistent with suggestions that hare densities remain relatively low in southern British Columbia and the northwestern United States (Chitty 1950; Dolbeer and Clark 1975; Wolff 1980)... Annual home ranges of resident lynx in the southern Canadian Rockies were considerably larger than those reported for most other studies employing the same estimators, regardless of prey density or geographic locale (Koehler and Aubry 1994; Poole 1994; Slough and Mowat 1996). XII, 6-7
2. In order for lynx to survive in many areas of its former range, small populations must be connected regionally into larger "metapopulations," and must readily disperse between populations.
Southern lynx populations appear to exist at lower densities and to have lower reproductive rates than northern populations (Chapter 13). Habitat heterogeneity is also much higher than in the taiga (Chapter 3); therefore, southern populations likely occur partly in areas which act as "sinks "and are dependent on immigration from "sources." II, 9-10
For most of the islands in a metapopulation to be occupied at given time, the colonization rate must greatly exceed that of local extinction. If subpopulations on islands are extinction-prone, then a stable metapopulation requires a high rate of dispersal between the islands. II, 5
3. Those lynx populations that are currently isolated from other populations in the U.S. and in Canada are particularly at risk of extirpation.
Arguably, the lynx in the northeastern United States are effectively isolated from the main Canadian populations by the St. Lawrence Seaway and from the Great Lake States by agricultural conversion and urban development. Similarly, boreal forests in Colorado and Utah are separated from the larger areas of boreal forest in Wyoming by at least 100 km. If these areas have become effectively isolated, then they represent special areas of concern and, if they still contain native populations, these populations are particularly endangered. II, 13
4. Further, the report warns against relying on reintroductions to restore fragmented lynx populations, but instead recommends maintaining regional connectivity wherever possible.
Because translocations and reintroductions are inherently risky even under optimal conditions, they should be used only when other management options have failed. Conservation objectives are more likely to be met by maintaining and/or enhancing habitat conditions for lynx to provide opportunities for them to recolonize former portions of their range. V, 12
B. Current management and conservation policies for lynx and their habitat are not adequate to address the threats to lynx survival.
We do not believe that a system of reserves maintained by policy or regulation, embedded in a increasingly fragmented and non-natural matrix, can provide for sustainable lynx populations. Inevitable large-scale catastrophes preclude this being a sustainable system from the standpoint of lynx conservation; catastrophes will remove reserves, and there is no mechanism for their replacement or restoration in a reserve/matrix approach. Allen and Hoekstra (1992) have argued that one role of management in sustainable ecosystems is to replace functions that are generally provided in the natural context, but have been lost due to human influences. For this reason, we argue for a system of active management in those land designations where it is permitted. Management of these lands must be cognisant of and limited by the dependency of various species on the condition of these areas given the likelihood of divergent management in adjacent private lands, as well as inevitable natural disturbances... The necessary regulatory framework must also be in place... XV, 6-7
Our challenge, from the perspective of maintaining lynx and their prey in the context of ecosystem management, is to design management strategies that result in dynamic, sustainable landscapes that approximate the composition of natural systems. XV, 10
C. Loss and fragmentation of lynx habitat due to forestry practices, roads, and other human activities and developments is the major factor in the decline of lynx that needs to be addressed.
Fragmentation of habitats occupied by lynx (including increased openings, higher road densities, exurban residential development, and wider use of snowmobiles and devices that compact snow in areas with deep, soft snow) is a plausible mechanism for the questionable conservation status of the lynx in the contiguous United States. IV,13
Because of the fragmented nature of landscapes and heterogeneous distribution of topographic, climatic, and vegetative conditions in western forests, lynx and snowshoe hare habitats there are more prone to a metapopulation structure, which has important implications for their population ecology (Chapter 2). This condition is exacerbated by the presumably greater human-caused fragmentation of lynx habitat in the south. XIV, 5
1. Past and ongoing forestry practices present a unique threat to lynx
In a cyclic system, there is no formal mechanism to generate stands or elements older than rotation age... escape of older elements is not effectively mimicked by embedding fixed reserves in a landscape of cyclic management... in areas subjected to large wildland fires, or where inholdings are managed for short-rotation timber yield using even-aged management, timber harvest (including salvage) may be inappropriate for decades... we would argue for a planned rate of disturbance somewhat less than the historically derived estimate. It is easy to increase the disturbance rate if desirable, but much harder to recover old-growth forests removed through overly aggressive management... X, 11-12
... models suggest that large proportions of young forest were characteristic of the boreal region but that fair amounts of quite old forest were part of the mosaic as well. These natural landscapes diverged significantly from even-aged silvicultural systems: fewer roads, more coarse woody debris, older age structures, and complex juxtaposition of different-aged stands. III, 35
2. Current silvicultural techniques are often detrimental to lynx
Snowshoe hares generally occur in areas of dense forest cover, including shrubs and "doghair" thickets of small trees (Chapters 6 and 7). These structures are common in naturally regenerating areas after fire, but do not result from standard, even-aged forestry practices (Daniel et al.1979). Thus, we believe that natural regeneration and stand development will likely benefit hares and, ultimately, lynx. XV, 14-15
Creative silviculture is required when management goals extend beyond wood production. This might translate to heavier reliance on natural regeneration after wildland fires. Where harvest mandates artificial regeneration in a short time frame, the planting might be clustered such that the time of early seral dominance will be spatially variable across a unit. If pre-commercial thinning is considered, it should be recognized that the usual objective of increasing the diameter growth of residual trees may be inappropriate for lynx. Leaving some doghair stands may be good for lynx; thinning others so heavily that additional conifer regeneration occurs in the unit may also be appropriate. Because fires leave large amounts of woody material standing and down, management should also leave substantial amounts of woody material in representative size classes, regardless of treatment. XV, 15
3. Logging is not an effective substitution for fire and other natural disturbances, because fire and other disturbances will continue to occur, and differences with roading, coarse woody debris, forest structure, and the larger forest mosaic.
For the boreal forest, there are several general principles that must be addressed in landscape management plans if harvesting or fire disturbance is to be incorporated:
1. The habitat will be a product of the cumulative effect of all disturbances. The substitution of logging for fire, for example, is only meaningful if fire can be successfully removed from the environment, and even then, logging will not totally mimic fire as a disturbance process because of roading and coarse woody debris differences.
2. Typical models used for fire history studies suggest that fire selected a range of stand ages to burn. Harvesting only the oldest ages will decrease the average stand age of the landscape and will remove the complex boreal stand structure that may be critical for lynx denning. Young and old stands need to be part of any landscape disturbance plan.
3. Size and juxtaposition of stands is critical. Most fires are small. Most of the landscape, however, is affected by larger fire patches, with unburned areas inside the fire perimeter (stringers, islands, fire skips). III, 34
4. Cases where logging may be beneficial to lynx by increasing hare production are likely to be rare, especially on dry sites.
We caution against uncritical application of ecological understandings derived from the North to southern lynx and we emphasize the potential importance of late-successional forests as habitat for hares, red squirrels, and lynx in the southern part of the range of the lynx. XIV, 1
In mesic forests... we argue that hare densities should be bimodal with stand age: highest in early seral conditions, minimal in closed-canopy mature forests, and reaching moderate densities in extremely old gap-phase forests. We do not, however, expect this pattern to be common on dry sites where erratic regeneration and the lack of tall deciduous brush often lead to very open conditions for extensive periods after disturbance. In these stands, hare habitat will only be produced in later seres. XIV, 10
We question the generalization that the best way to provide habitat for lynx prey, including hares,is to create early-successional forest. On mesic sites, the highest hare densities are generally found in sapling-stage forests after disturbance, but squirrels are absent from these sites. We believe the data, though sparse, also suggest that old gap-phase forests provide a combination of high numbers of squirrels and moderate densities of hares on many sites. Additionally, site moisture appears to be an important correlate of shrub and sapling densities in the early stages following disturbance and, in dry areas of the West where post-disturbance regeneration is erratic, gap-phase old-growth forests may provide relatively higher densities of small-diameter woody stems compared to earlier stages of succession on the same sites. In areas where boreal forests are highly fragmented, older forests may be an important stabilizing element. Because small areas of boreal forest can be highly altered by single disturbance events, such as fire, hare dynamics associated with post-disturbance conditions will be transient. Older forests are temporally stable, will produce hares in lower but more reliable numbers, and provide squirrels as alternative prey. On dry sites, where young forests do not reliably produce hare habitat, older forests may provide a critical source of hare habitat. XIV, 14
5. The report provides added evidence of the importance of maintaining late successional stands with large woody debris on the forest floor for lynx denning habitat.
In both northern and southern regions, lynx occur predominantly in habitats where snowshoe hares are abundant, especially early successional stands with high stem densities. However, in southern boreal forests, such habitats appear to be used primarily for hunting; all known den sites in southern regions were located in mature forest stands with large woody debris. XIII, 2
The structural components mature forests and high woody debris associated with the natal den in Wyoming were similar to those associated with dens in Washington. XI, 12
D. Logging and the subsequent increased access into lynx habitat via the associated forest roads may be contributing to fragmentation and enhancing competition from other "generalist" predators
In general, intensive forest management and concomitant fragmentation of habitat via timber harvesting and road systems are more prevalent in southern boreal forests compared to the taiga. Thus, human-mediated increases in potential competitors and predators may present a more serious threat to lynx populations in southern boreal forests than in the taiga. XIV, 13
Recreational snowmobile use has expanded dramatically in the contiguous United States in the past 25 years, with hundreds of thousands of km of trails (>19,000 km of groomed trails in Maine alone) within the pre-settlement range of the lynx (Maine Snowmobile Association, World Wide Web site, Zesiger 1997). Various unpublished accounts describe snowmobile and snowshoe trails facilitating access by coyotes to areas used by hares and lynx. In the Yukon, coyotes use both snowshoe and snowmobile trails (O Donoghue, personal communication). This facilitation of travel, in general, could help explain possible lynx reductions in the West via human-facilitated competition from coyotes and other generalist predators. Better understanding of this postulated relationship is critical. IV, 12-13
E. While the effects of roads on lynx are hard to quantify, there are both direct and indirect negative effects of roads at every level.
1. Roads were found not to affect lynx movements in Washington State, but these were specifically "narrow, forest roads at relatively low densities," and the authors also qualify their finding with the statement, "we caution that our analyses did not address potential indirect effects of roads on habitat quality for lynx" (Chapter 10, p.27).
2. Apps found that roads in his study area did affect lynx movements. He also suggests a mechanism for why the effects of roads on lynx may be more significant than movement data may suggest:
The likelihood of highway crossings by resident lynx can be expected to vary among home ranges according to proximal habitat conditions, width of road allowance and traffic volume, and perhaps by the animals sex and reproductive status. Although my analysis did not account for these factors, all lynx crossed highways less than random expectation within their 95% UD home ranges, suggesting that highways influenced lynx movements. Although my analysis only considered the influence of highways within home ranges, they may also influence home range selection just as dominant natural features can (Koehler and Aubry 1994), and this would decrease the substantive influence apparent within home ranges. XII, 9
3. Apps also cites a relevant study in Wisconsin where bobcats avoided roads:
... bobcats in Wisconsin selected home ranges with lower densities of secondary roads and crossed paved highways less than expected, a function of vehicle traffic levels and juxtaposition of preferred habitat to roads (Lovallo and Anderson 1996). XII, 9
4. The report mentions less-direct effects of roads, including the fact that increased access into lynx habitat for both people and competitors would likely result in increased lynx mortalities.
As in the taiga, we found little evidence that roads represented a significant disturbance or mortality factor for lynx. Roads into lynx habitat may, however, provide access to generalist competitors, such as coyotes and bobcats. XIII, 2
Roads into areas occupied by lynx may pose a threat to lynx from incidental harvest or poaching (Koehler and Brittell 1990), increased access during winter for competing carnivores, especially coyotes (Chapter 4), disturbance or mortality from vehicles, and loss of habitat. XIII, 19
F. Lynx conservation today requires a larger spatial scale than has been considered under past and current management, where federal protection and even international protection is required.
Our analysis of the current and historic distribution of lynx populations in the United States indicates that large, contiguous areas of suitable habitat are necessary for population persistence (Chapter 8). XV, 8
Because lynx occupy large home ranges and occur at low densities (about one lynx/50 km 2 ; Chapter 13), the long-term viability of lynx populations cannot be achieved at the spatial scale of relatively small parcels of public land, or even larger units such as individual National Forests or National Parks. Consequently, we believe that lynx conservation in the contiguous United States can only succeed as part of an ecosystem management strategy that is designed to address the needs of a variety of potentially conflicting resource uses over long periods of time and broad spatial scales. XV, 2
The following calculation (included here for illustrative purposes only) provides a sense of the smallest scale at which conservation planning will need to be addressed. The estimated density of a local population of 25 resident lynx in north-central Washington studied with radiotelemetry from 1980 to 1987,was about one lynx per 50 km 2 (Chapter 13; Brittell et al. 1989, unpublished; Koehler 1990). Thus, conservation of this small group of animals, which is probably not viable as a geographically closed population (see Chapter 2), would require a planning area at least 1,250 km 2 in size (25 x 50 km 2 ). However, this estimate represents a minimum area requirement over a relatively short period of time; to provide sufficient habitat for the population size to fluctuate around a long-term mean of 25 animals, the actual conservation area would need to be considerably larger. XV, 9
G. It is no longer appropriate to rely on Canada to refuel our own lynx populations.
We cannot assume that lynx populations in the contiguous United States will be maintained by dispersal of lynx from Canada, nor that connectivity with larger habitat areas in Canada will be maintained in perpetuity. Although cooperative conservation efforts with Canadian land management agencies should be explored in all areas of adjacent lynx habitat, we believe that lynx conservation efforts in the contiguous United States should be addressed at geographic scales that will provide for the persistence of resident populations of lynx, regardless of periodic augmentations that may occur from other areas. Clearly, ecoprovince-wide planning is necessary to provide the broad-scale information necessary for effective conservation of lynx. XV, 9
H. The report emphasizes the need to address lynx mortality due to legal, incidental and illegal trapping.
Although legal harvest is no longer a conservation concern, human-caused mortality is believed to be additive in the low-density lynx populations characteristic of southern boreal forests (Koehler 1990; Table 13.3). If so, illegal or incidental harvest could significantly reduce population numbers of lynx in southern regions. XIII, 19
I. Preliminary results from field work in Montana indicate that lynx numbers in the state may be lower than previously believed, since lynx are found to have large home ranges within the study area, and that the study area may be among the most productive lynx habitat in the state.
Preliminary telemetry data suggest that lynx in Montana and Wyoming have large home ranges; this result supports the Koehler and Aubry (1994) contention that lynx from southern lynx populations have large spatial-use areas. XI, 1
The study area in Montana is located in the Clearwater River drainage, near the town of Seeley Lake. This area is about 1,800 km 2 , extending east to west from the Swan Range to the Mission Mountains, and north to south from Lindbergh Lake to Salmon Lake. Lynx harvests (1977-1994) and track surveys suggest this area may support the highest density of lynx in Montana (Brian Giddings, personal communication). XI, 2-3
J. The report provided added evidence that lynx are indeed residents of Wyoming and Idaho, and that the Wyoming lynx population may have special importance for lynx conservation since it is the southernmost known population:
In Wyoming, the female produced a litter of four kittens (two males, two females) on about 27 May 1998; all kittens were alive on 14 June 1998 when they were ear-tagged. However, based on snow tracking, the kittens were not with the female in November and presumably had died. In May 1999 the same female produced two additional kittens. XI, 10
Understanding the ecology of lynx in Wyoming is critical to conservation planning because these animals represent the southernmost known population. XI, 2
K. The report emphasizes the urgency to protect the other small and potential disjunct lynx populations in the Northeast, Lake States, and southern Rockies.
Until we understand the nature of geographic variation in lynx populations,it would seem prudent to assume the existence of important genetic and non-genetic differences among populations, especially those that are distant and/or relatively isolated... it is critical to consider both inherited and non-inherited variation when manipulating lynx populations or managing their habitat. We recommend that managers assume the existence of important genetic and non-genetic differences between distant and/or relatively isolated lynx populations until proven otherwise. V, 11-12
In sum, the scientific basis to protect lynx under the Endangered Species Act has never been stronger. We urge the U.S. Fish and Wildlife Service to delay no further in granting the lynx the protection it deserves and requires as a species in imminent danger of extirpation from all areas of its current and former range in the contiguous United States. Thank you for the opportunity to comment,
Respectfully submitted,
David Gaillard
Predator Conservation Alliance (formerly, Predator Project), PO Box 6733, Bozeman, MT 59771
Mike Medberry, American Lands Alliance, 910 W. Main St. #228, Boise, ID 83702
Jasper Carlton, Biodiversity Legal Foundation, PO Box 278, Louisville, CO 80027
Chuck Pezeshki, Clearwater Biodiversity Project, 1031 Spring Valley Rd., Troy, ID 83871
Jeffrey Berman, Colorado Wild, PO Box 1525, Boulder, CO 80306
Kristin Ruether, Friends of the Clearwater, PO Box 9241, Moscow, ID 83843
Kathy Richmond, Friends of the West, HC 67, Box 680, Clayton, ID 83227
Tim Stevens, Greater Yellowstone Coalition, PO Box 1874, Bozeman, MT 59771
Ric Bailey, Hells Canyon Preservation Council, PO Box 2768, LaGrande, OR 97850
John McCarthy, Idaho Conservation League, PO Box 844, Boise, ID 83701
Franz Camenzind, Jackson Hole Conservation Alliance, PO Box 2728, Jackson, WY 83001
Terrence Sawyer, The Lands Council, 517 S. Division St., Spokane, WA 99202
Susan Lenard, Montana Audubon Council, PO Box 595, Helena, MT 59624
Bob Decker, Montana Wilderness Association, PO Box 635, Helena, MT 59624
Mitch Friedman, Northwest Ecosystem Alliance, 1421 Cornwall Ave., Suite 201, Bellingham, WA 98225
Kristin DeBoer, RESTORE: The North Woods, PO Box 1099, Concord, MA 01742
Rob Edward, Sinapu, PO Box 3243, Boulder, CO 80307
Keith Hammer, Swan View Coalition, 3165 Foothill Road, Kalispell, MT 59901
David Zaber, Western Lakes Wildlife Center, 6103 Gateway Green, Monona, WI 53716
Craig Gehrke, The Wilderness Society, 413 West Idaho St., Suite 102, Boise, ID 83702
Nancy Zierenberg, Wildlife Damage Review, PO Box 85218, Tucson, AZ 85754
Caroline Byrd, Wyoming Outdoor Council, 262 Lincoln, Lander, WY 82520