Predator Control

Background

Lethal control of predators such as coyotes, cougars, fox, weasels, wolves and bears is allowed on public lands by law under the Animal Damage Control Act of 1931. The purpose of the Act was to protect human health, safety, and property, including crops and domestic livestock, from damage caused by wildlife. Predator control is also implemented as a wildlife management technique to boost population levels of specific target species. For example, coyotes and cougars may be removed to help build up a population of bighorn sheep or antelope. In Alaska, wolves are sometimes killed to boost moose populations in areas where rural residents rely on subsistence hunting of moose as a primary food source.

One main reason that lethal predator control is implemented in designated wilderness is to reduce the risk of predation on domestic livestock that graze on public lands. Livestock grazing occurs in most BLM Wilderness and in some national forest wilderness. Essentially no livestock grazing occurs throughout national park or national wildlife refuge wilderness. It is estimated that 80% or more of the total acreage in the NWPS is free of livestock grazing. This means that lethal predator control is not widespread throughout the Wilderness System, but where it does occur for purposes of livestock protection it represents a gross manipulation of natural processes to benefit private commercial interests, and is biologically and ethically questionable.

A second major reason that lethal predator control takes place in designated Wilderness is as a management tool aimed at stabilizing or boosting the populations of other wildlife species. This most frequently occurs in national wildlife refuge Wilderness. Examples include possible removal of predators to protect a threatened or endangered species such as the Sonoran Pronghorn Antelope, and control measures to protect the nests and young of various bird species, many of which are popular game species. Although not a predator, beaver are also trapped on some refuges if their dam-building activities interfere with intensive management of levees and water channels aimed at maximizing habitat for waterfowl.

Predators form an integral part of a naturally functioning ecosystem. They are keystone species that play an effective role in maintaining healthy populations of prey species such as ungulates and small mammals. Feeding largely on herbivores, predators help prevent overpopulation that can lead to habitat damage due to overgrazed vegetation. In Wilderness, all indigenous species have a place, and species populations should not be artificially manipulated through predator control to reduce certain species in order to augment the populations of other species more favored by humans.

Predator Control and Wilderness

Within Wilderness, predator control should only be considered if it is demonstrated to be necessary to the survival and recovery of a threatened or endangered species. Since the presence of a full complement of indigenous wildlife is a valuable component of an area’s Wilderness character, taking steps to prevent the loss of a T & E species may be justified as the ‘minimum requirement’ necessary to protect Wilderness character. Losing an indigenous species to extirpation or extinction diminishes Wilderness character. For this reason intentional manipulation of habitat and wildlife may be appropriate in such circumstances if it is the minimum action necessary to prevent loss of an indigenous species and diminishment of Wilderness character.

No lethal predator control should be allowed in Wilderness for purposes of livestock protection or game management. By law, land managers are to preserve wilderness as a place that is untrammeled by intentional human manipulation. The presence of native wildlife, including predators, at naturally occurring population levels are an integral aspect of wilderness character. Although predator control for livestock protection is allowed by the Animal Damage Control Act of 1931, that Act does not make predator control a mandatory action that managers must allow at the request of a livestock permittee. In contrast, managers do have a mandatory statutory obligation to preserve an area’s wilderness character, which includes protecting indigenous predators.

It is falsely believed that predators pose a serious economic threat to livestock interests. The Predator Conservation Alliance, an organization that provides scientific research to public agencies and conservation groups, reports that “predation accounts for a small fraction of livestock loss, with the majority of livestock deaths being due to disease and harsh weather.” Furthermore, in some states ranchers are reimbursed by the state Fish & Game agency for livestock lost to predation.
Permittees know there are risks of predation when they choose to graze livestock on public lands. There are various non-lethal measures a permittee can take to significantly reduce that risk, primarily through better husbandry techniques. The public should not have to support commercial livestock grazing by giving up native predators on our public lands.

Similarly, manipulating game species populations through predator control trammels natural processes and degrades the meaning of Wilderness as defined by § 4(b) of the Wilderness Act. The Act does not allow wilderness to be manipulated and trammeled simply to augment recreational opportunities such as hunting. If a game species population is declining, then fewer hunting permits should be issued, not rush to undertake lethal predator control. Many game species such as bighorn sheep have wide naturally occurring population fluctuations, and these should be allowed to occur in wilderness. The Wilderness Act did not intend for Wilderness to be treated as a game farm, where we intensively manage for a few favored species at the expense of others in the ecosystem.

In addition to unnecessarily trammeling natural processes, many forms of lethal predator control pose risk to non-target species. Leg-hold traps and snares are not species-specific, and often capture creatures other than the species intended, including some that may be on the Endangered Species list, such as bald eagles. Poisons also are not species-specific. The scent bait used to lure mammalian predators to sodium cyanide cartridges called M-44’s is an attractant to any species in to the Canid family. While coyotes may be the intended target species, M-44’s can and do lure foxes, bears, badgers, dogs, and others. These types of indiscriminate assaults on wildlife in wilderness degrade Wilderness character, pose artificially-induced health and safety risks, and are not justified for purposes of artificially augmenting game populations or preventing predation on commercial livestock.