Predator Conservation Alliance's response to the USDA/APHIS/WS and IDFG Clearwater National Forest Proposal

written by David Gaillard, Program Associate

February 6, 2001

Mr. Mark Collinge, Director
USDA/APHIS Wildlife "Services"
9134 W. Blackeagle Drive
Boise, ID 83709

Dear Mr. Collinge:

It is difficult to remain civil while commenting on this proposal to kill as many as 75 black bears (just as the newborn cubs are emerging from their dens) and approximately 10 mountain lions in a grand "experiment" to generate greater numbers of elk to hunt. This proposal is an offense to every American and Idahoan who cares about wildlife. To fund this project with our tax dollars is still less defensible.

Predator Conservation Alliance, Friends of the Clearwater, and the majority of Americans nationwide who support wildlife and wild country, are increasingly fed up with Idaho's audacious, arrogant and uninformed bias against its native predator species, and will not stand for a federally funded agency to be its operatives. We are writing on behalf of Predator Conservation Alliance, Friends of the Clearwater, and our 2,800 members nationwide (including more than 300 members in Idaho) to urge you to do all that is within your power to put an end to this wrongheaded proposal - please pursue the "No Action" alternative.

If Wildlife Services insists upon wasting our tax dollars on an Environmental Assessment regarding this issue, we demand that it thoroughly investigate the following issues:


-Has there already been a thorough literature search of the effects of black bears and mountain lions on elk productivity? What rates of elk predation by black bears have been recorded elsewhere? Is this truly a plausible mechanism for depressed elk numbers?


-Have elk numbers in the area been thoroughly monitored to indicate that there is indeed a decline? If so, what environmental and other variables have been acting on the population that are also plausible mechanisms for this decline? For example, we understand that the study area has received a dramatic increase in use by off-road vehicles (ORVs). Have the effects of ORV use on elk been examined?


-Has the proposed "study" design gone through a comprehensive scientific peer review process? What is the likelihood that this so-called study will advance scientific knowledge with any degree of certainty?


-What are the projected benefits to science from obtaining this information, compared to the costs of this study, and the social costs to Idaho sportsmen and Idaho in general, when the public realizes the government is killing certain wildlife in an effort to increase other wildlife populations for commercial hunting?


-What are the projected economic benefits of the "study," compared to the economic costs both of study itself (hiring professional wildlife killers, and flying them, baits, etc. around in helicopters), and the costs due to an anticipated economic backlash from a public outraged at the killing of innocent bears and lions?


-The "invitation for public involvement" asserts that the black bear and mountain lion populations are, "stable to increasing" in the area. Where are the data and analysis to support this claim? Have these data and analysis been subject to scientific peer review? What indication do we have that the loss of an additional 75 black bears and 10 lions in the first year of this project alone is sustainable?


-The "invitation for comment" notes that increased hunting seasons and limits failed to result in more dead bears. Are there any data to indicate that hunter effort was indeed greater due to the liberalized regulations? If so, and greater hunter effort has failed to result in more bear mortalities, does this not contradict the claim that the bear population in the area is stable or increasing?
How rigorous are the results we can expect from the proposed "study" design, given the many variables within the system that are impossible to control? For example, on the Hart Mountain Refuge in Oregon, a similar proposal to enhance pronghorn antelope numbers by killing coyotes was recently defeated, and pronghorn numbers rebounded strongly the following year, despite the lack of any coyote control. If the coyotes had been killed as planned, presumably that study would conclude that coyotes had been suppressing antelope numbers. Is there not a risk of this same type of "false positive" result from this proposed "study"?

In its comments in response to Idaho's recently adopted predator policy, Predator Conservation Alliance asserted the following, on behalf of Friends of the Clearwater and 20 other conservation organizations who co-signed the letter, representing hundreds of thousands of Americans nationwide, and approximately 10,000 Idaho residents:

"The draft policy directs the Department to kill/control predators where there is "evidence" that predators are precluding other management objectives. As would be the case before killing/controlling other wildlife species, evidence must be irrefutable that both: (1) predatory wildlife are indeed a primary threat to an overriding Department objective (as opposed to habitat loss and destruction, for example), and (2) killing or otherwise controlling predators would effectively resolve the problem. We believe that the cases where these preconditions can be met are rare indeed, and may be limited to areas where exotic predators have been introduced, such as brown tree snakes in Guam, for example."

Consistent with this position, we are adamantly opposed to the current black bear- and mountain lion-killing proposal, thinly disguised as a "study."

In sum, if the Idaho Department of Fish and Game proceeds with this proposal, it will pit a minority of elk hunting outfitters against Idahoans and the American public who care deeply about all wildlife, and want to be careful stewards of all wildlife. The natural outcome will be to give the hunting community a big black eye in the view of the greater public, and only add fuel to mounting efforts to outlaw hunting entirely. If USDA/APHIS Wildlife Services plays a leading role in this proposal, it will only uphold the reputation put forth by an increasing tide of critics: a runaway government killing machine, spending tax dollars in direct contradiction to the wildlife conservation ethic so many Americans hold dear. The natural outcome will be an end to the federal funding of Wildlife Services.

Please make sure to keep Predator Conservation Alliance and Friends of the Clearwater informed of any developments on this issue, because if it survives the environmental assessment process long enough to be submitted for a formal public review, we intend to play an active role to ensure that the public learns of this proposal, and to ensure that it does not proceed unless the majority of the public supports it. Thank you for your consideration.

Sincerely,

David Gaillard
Predator Conservation Alliance
P.O. Box 6733
Bozeman, MT 59771
406-587-3389

Gary Macfarlane
Friends of the Clearwater
P.O. Box 9241
Moscow, ID 83843
208-882-9755

cc: Governor Dirk Kempthorne
IDFG Commissioners
IDFG Director
Regional Director, U.S. Forest Service
Supervisor, Clearwater National Forest
Idaho Statesman