Introduction
WildLands Defense (WLD) has watched for years as the irrational hatred of native carnivores in the Western United States has fostered an ongoing landscape-level extirpation of apex predators resulting in loss of ecosystem integrity and myriad environmental values across federal public lands belonging to all Americans. In spite of the growing body of scientific literature demonstrating native carnivores’ essential role in the preservation and restoration of scientific, environmental, aesthetic, recreational and spiritual values, and in spite of the general public’s growing appreciation for native predators’ ongoing existence in ecologically relevant populations, public land managers have failed to lawfully protect our lands and the habitats and wildlife communities that call them home.
Wolves and coyotes are slaughtered in retribution for minor and often questionable livestock losses on public lands. Members of WildLands Defense have monitored wolves and livestock grazing allotments for years, witnessing innumerable examples of livestock operations benefitting from public leases/permits that include no reference to nor regard for easily implemented, enforceable operating protocol that would largely assuage inevitable conflicts before they occur at a fraction of the cost of extermination efforts. Furthermore, agencies’ routine refusal to adequately monitor and enforce the terms and conditions of permits and operating instructions that do exist has resulted in lackluster grazing practices and negligent animal husbandry on public lands, a management shortcoming that has and continues to foment conditions ripe for conflict with native predators.
Year after year of failed grazing management by public land managers and permittees has fanned the flames of an irrational hatred of wolves and other native carnivores. Many wolves, coyotes, and other native predators have been locally extirpated or rendered ecologically ineffective as a result of livestock-predator conflicts that could be avoided and minimized.
Many environmental impacts occurring as a consequence of locally extirpated predator populations are due to public land managers’ flagrant derelictions of their lawful duty to control how, when and where livestock grazing is conducted on public lands.
Put simply, a long overlooked and underappreciated strategy to reducing livestock conflicts is to appropriately control livestock use and impacts on public lands.
Predators Are Essential Members of the Natural Community
Predators’ ecologically relevant populations on public lands facilitates a balance among the biotic community altering ungulate behavior and other dynamics that play an integral role among the natural community that is essential to preserve and restore the diversity and vitality of habitat conditions and wildlife populations at the landscape level. Scientists have referred to this dynamic among apex species as the “trophic cascade” and have described the importance that predators’ existence on the landscape in engendering an “ecology of fear” that fosters balance among habitats and a resulting diversity among species that lends landscapes dynamism and vitality essential to its very character.
Public recognition of these relationships on the ground, and the conservation ethos it engendered, was first articulated by legendary conservationist Aldo Leopold who decried his own role in lethal wolf control for the federal government after gaining an appreciation for the central role of top predators in ecosystem integrity (Leopold 1949 – Leopold, A.S. 1949. Thinking like a mountain, pp. 129-130 In A Sand County almanac and sketches here and there. New York, Oxford University Press.).
Ecosystem science has progressed a great deal since Leopold’s 1949 essay and a flood of scientific literature has validated his prescient recognition of the integral environmental values that intact ecosystems enjoy when influenced by ecologically relevant communities of apex predators. Unfortunately, given the existing approach to conflict, the bulk of scientific literature likewise vindicates the other side of the coin, namely, the pervasive ecological impact, reduced dynamism, vitality and the general simplification of habitat and wildlife communities that occurs when land and wildlife managers eradicate predators from natural communities (Estes et al. 2011 – Estes, J.A., J. Terborgh, J.S. Brashares, et al. 2011. Trophic downgrading of Planet Earth. Science 333: 301-306.).
There is no question that activities which result in the removal of predators’ essential ecological niche substantively and substantially impacts environmental values at the landscape scale.
Public Land Management Permitting of Public Lands Ranching Fosters Negative Impact to Native Predators and Myriad Environmental Values
The Forest Service and Bureau of Land Management’s respective administration of public lands livestock grazing is the chief proximate cause of conflict between domestic livestock and native predator communities. In spite of the undeniable advances of science and the American public’s growing appreciation for predators, federal land managers have failed to acknowledge and consider their own culpability in land-use decisions that foster conflict. Despite the ongoing escalation of social and political controversy, it appears to the public that the Forest Service and BLM de facto management has no clear plan, nor any intention to rationalize its federal grazing program in accordance with its existing legal and fiduciary duties to consider the environmental consequences of its actions and administer land-use management prescriptions that ensure reasonable consideration of the public environmental interest, a failure that undeniably results in significant impact to habitat and ecosystem values.
WLD’s founders’ and members’ have decades of experience monitoring public lands ranching allotments throughout the West, an ongoing experience that leads us to the undeniable conclusion that federal land managers’ permissive permits to graze public lands results in lackluster and irresponsible management of livestock grazing. This irresponsible management leads to trailing and herding practices that pay no regard to easily implemented conflict avoidance strategies including responsive herding (to avoid wolf denning and rendezvous sites), or even the most basic measures that would enforce common-sense requirements to deny the unattended lambing of domestic sheep in known wolf habitat on remote public lands.
When public land managers permit public land-uses that can be reasonably anticipated to engender conflict with predators, and other conditions of the natural world, the most economically rational, ecologically sound, and socially responsible means of ensuring compliance with the public environmental interest is for land managers to recognize their fiduciary duties and legal obligations to conduct adequate environmental review of their lackluster terms and conditions and the environmental consequences to predators and resulting environmental values impacted. Federal land managers must implement, as enforceable terms and condition of permitted use, grazing management regimes that require preventative measures, avoidance techniques, public education and non-lethal methods of controlling conflict between public lands ranching and the native predators that inhabit public lands subject to livestock use. Throughout such a management regime there must be ongoing research into the efficacy and costs vs. benefits of any control programs.
Financial Costs of Federal Lands Managers’ Failed Management
It is estimated that at least 5 taxpayer dollars are squandered to kill every coyote held responsible for the loss of one dollar’s worth of livestock, a figure that does not include the value of the damage to the landscape and lost forage for the livestock caused by any compensatory increases in jackrabbits when coyotes are removed (Alcock 1990 – Alcock, J. 1990. The cost of coyote meat. Los Angeles Times, 25 March 1990.).
Cattle losses to all predators account for only 5.5% of total mortality (USDA 2012 – [USDA] United States Department of Agriculture. 2012. Cattle death loss. USDA National Agricultural Statistics Service, Agricultural Statistics Board, released 12 May 2011.) and even in the northern Rocky Mountain wolf recovery zone, wolf predation accounts for only a small fraction of predator losses (USFWS 2012 – [USFWS] U.S. Fish and Wildlife Service. 2012. Gray wolves in the northern Rocky Mountains; www .fws.gov/mountain-prairie/species/mammals/wolf/.
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In times when fiscal constraint is demanded, we believe programs that carelessly kill rare species and indiscriminately kill a great diversity of non-target species should be defunded and discontinued, especially given that those programs work at cross purposes to federal and state programs (e.g., endangered species recovery) starved for funds to restore these same species and ecosystems.
Reducing wolf populations causes “mesopredator release” and increases coyote predation (Prugh et al. 2009 – Prugh L.R., Stoner C.J., Epps C.W., W.T. Bean, W.J. Ripple, A.S. Laliberte, J.S. Brashares. 2009. The rise of the mesopredator. BioScience 59: 779–791.).
A massive campaign to exterminate wolves and coyotes across the West was begun in the early 1900s; by the 1920s, rabbits had so overpopulated the region that another massive campaign was begun to reduce their numbers (600,000 rabbits were killed in one year in Idaho by government hunters; Hawthorne et al. 1999 – Hawthorne, D.W., G.L. Nunley, and V. Prothro. 1999. A history of the Wildlife Services program. The Probe (Newsletter of the National Animal http://digitalcommons.unl.edu/icwdmprobe/43.). Apparently WS never did make the obvious connection between coyote control efforts and rabbit population numbers.
WS’s collaboration with the State of Idaho in its excessive zeal to remove most of those wolves that the government has restored, for reasons that are not scientifically supported, is perhaps the most troubling of all. We believe an agency of the federal government should not be in the business of helping any state (or private entity) achieve such a politically motivated and scientifically unsupported goal.
New Paradigm for Public Lands Livestock Management Must Be Implemented
Federal land management agencies must require reasonable and prudent controls on grazing, and accountability from all livestock permittees and lessees who use the public’s land. The needs of native predators, and conflict reduction, must be at the forefront of management going forward.
Grazing Permittees Must Be Required to Sign a Hold Harmless Agreement
The agency must require all permittees to sign a hold harmless agreement as part of any grazing permit or lease. This must start with the 2015 Annual Operating or Grazing Plan.
The hold harmless agreement ensures the permittee accepts potential occasional losses of livestock as part of enjoying the extraordinarily subsidized privilege of operating on public lands. The hold harmless grazing agreement must guarantee that native predators will not be killed, trapped, snared, shot, poisoned, or otherwise harmed and persecuted by the permittee/lessee, federal agencies including Wildlife Services, state and county agents/actors or other parties if livestock are injured or killed while on public lands under a federal grazing permit or other authorization.
Rationale: Grazing on public lands is nearly free. U.S taxpayers extraordinarily subsidize the commercial production of livestock on public lands. One way in which they do so is that public land ranchers pay rock-bottom rates of $1.35 per Animal Unit Month (AUM = one cow and calf, or five sheep and numerous lambs). This is far below costs for equivalent private pasture that can run anywhere from $12/AUM to $25/AUM. Agencies routinely excuse this extreme subsidy under the auspice that the wild conditions of public lands, including the presence of native predators, necessitate additional management costs that private leases often do not require. However, despite their use of this rationale as an excuse to charge below-market rates to lease public lands, public land and wildlife agencies have not required any additional management shown to reduce livestock grazing’s conflict with native predators on the landscape. If agencies are to excuse this extreme shortchanging of the American public—in both payments recovered for use and in the degraded condition of wildlife and habitat—on account of additional management costs necessary to reduce livestock conflicts with native predators, then it’s time the agencies began enforcing the very management protocols necessary to reduce livestock-predator conflicts that they cite. At the very least agencies must ensure that native predators are held harmless where livestock permittees fail to implement the management necessary to prevent and mitigate livestock-predator conflict. The public is already paying for it.
Instead, in spite of recent science demonstrating that “control”/slaughter of wolves may actually increase likelihood of future depredations, a bloody campaign by Wildlife Services (WS) continues to eradicate predators for permittees, even at times when no livestock have been recently taken, at great cost to tax-payers, native predator populations, and the vibrancy and diversity of wildlife communities on public lands. Lethal devices used by WS threaten the public and have injured and killed dogs. Recreation and a broad spectrum of public uses are diminished on public lands by livestock grazing impacts to fish, wildlife and aesthetic natural settings. Local economies are increasingly based on tourism and wild lands recreation. These are notably harmed by livestock grazing damage to waters, fish and wildlife habitats and wild lands all impacts of which are compounded by the eradication of native predator populations.
Agency Must Ensure Habitat Security for Wolves and other Native Predators Through Thorough Baseline Inventories and Application of Avoidance Mitigation
Thorough baseline inventories for native predator use of grazing allotments and surrounding lands must be conducted as part of all agency activity planning processes.
Methods such as animal observations, cameras, hair and scat samples should be used to do this. This must be coupled with a biological assessment by a carnivore biologist examining the land area to determine potential suitability for predator occupation.
Due to the severe persecution of wolves and other native predators in this region, large areas of suitable habitat may be unoccupied but are in fact suitable for occupancy once reasonable and prudent non-lethal predator conflict avoidance measures are implemented by federal and state agencies.
Thorough inventory and assessment is necessary to establish a firm baseline of native predator use of the landscape during all seasons of the year. As part of this assessment, the agency must also consider the full body of cumulative disturbances and threats to habitats and viability faced by the local population. Conservation, enhancement and restoration of apex predators and fully functioning native ecosystems must be the goal.
Only after thorough assessment can the agency determine what lands, if any, in an allotment or watershed are suitable for imposing continued livestock grazing disturbance and conflict.
Large blocks of livestock-free lands must be provided during sensitive periods of the year for native carnivores.
Predator social systems must be respected. Research increasingly shows that maintaining wolf pack structure, established breeding pairs of coyotes, etc. all serve to reduce livestock predation. Predator use of the landscape must be respected and protected- denning sites, rendezvous sites, winter habitats, etc.
Federal and state land managers must immediately embark on assembling this information and conduct the associated analysis.
Immediate Management Actions
Management Actions that must be immediately implemented as part of any grazing occurring in 2015 and the future. These measures, and others based on public land manager’s past experience of conflict location must be immediately incorporated into Annual Operating Instructions and Annual Grazing Plans. This list is not all inclusive, but should be viewed as a non-exhaustive starting point with which to build upon.
These management actions include:
- Prohibit turnout of livestock in areas where wolves and other native predators are denning/birthing, at assembly sites, or in areas of high vulnerability to predation (e.g. areas hard for humans to diligently access and control livestock use and movements, areas of past depredations, etc.).
- Reduce Predator Attractants: Immediately remove sick, weak, injured and dead livestock and carrion associated with the livestock grazing operation from public lands. Properly dispose of dead livestock in a manner that does not merely shift conflicts (such as open bone yards that lure in predators).
- Prohibit calving/lambing and other activities that result in afterbirth, and vulnerable livestock on public lands.
- Require twice daily counting by herders of all livestock authorized to be grazing in each pasture or unit. Allow only the number of livestock to be grazed that can be readily controlled and counted twice daily. Require weekly written reporting of counts to agency.
- A percentage of all cattle or sheep grazed must wear radio transmitter devices. This data must be transmitted to a public website.
- Herders must be present around the clock in sufficient numbers to control livestock, reduce stray livestock, and detect predators to the best of their ability before predation occurs.
- Require permittees participate in predator-conflict avoidance training, including training in use of non-lethal measures such as fladry, LED lights or other devices.
- Use of vicious guard dogs must be avoided due to public safety concerns. All guard or herding dogs must be neutered.
Visitors to public lands are frequently dismayed by trespass livestock, dead/putrefying cattle and sheep carcasses left in and along streams, and other signs of negligent public lands permittees. By requiring that reasonable and prudent predator conflict avoidance measures are part and parcel of any authorized grazing that occurs on public lands the agency will not only aid in reducing predator conflicts, it will also help alleviate the myriad conflicts of livestock grazing disturbance with recreational, cultural, aesthetic, spiritual and other uses of the public lands. Posting livestock whereabouts in real time on agency websites will also aid the public in avoiding the immediate impacts of livestock stench and manure/waste, human contraction of livestock-borne disease, biting insects, noise, and denuding of wildflower meadows and stream bank areas.
Thriving Native Habitat for Predators and Prey Must Be Goal of Agency
The agency must require that its management actions provide thriving populations of apex and other native predators on public lands.
As part of a necessary capability, suitability and sustainability study, public land management agencies must make a valid, science-based determinations that grazing will not adversely impact native carnivore behavior patterns and use of the public lands. Conservation, enhancement and restoration of their habitats and populations must be the goal.