[Denveraudubon] regulations for predator damage control in wilderness areas

[Pauline P Reetz]

LETTERS ARE NEEDED BY AUGUST 7TH  on the following issue:
 
The US Forest Service is changing its handling of predator damage
"management" or control, in wilderness areas and research natural areas
on Forest Service lands.  Wildlife Services  used to be called "Animal
Damage Control" (ADC) and was under the US Fish and Wildlife Service for
many years.  Their biggest job was to kill coyotes in any way, shape or
form, but they took out other predators as well as rodents.  They also
went after large concentrations of birds like grackles, starlings, crows,
etc. that were perceived to threaten crops or human health.  Some years
ago ADC was moved into the Department of Agriculture and its name was
changed to Wildlife Services.

The Forest Service signed a Memorandum of Understanding with Wildlife
Services in 1993 which was revised in 2004, and the proposed changes are
to "further refine and clerify agency roles and procedures" to be
consistent with this latest version.  Basically, leadership and control
of the animal damage control process are being handed over to Wildlife
Services;  the Forest Service can object if they think wilderness
resources would be damaged.  

The proposal appeared in the Federal Register on June 7.   It  uses all
the right key words but the really objectionable part comes in later when
the notice says that "landing of aircraft and use of motorized equipment
and mechanical transport"  can be allowed if authorized by the Regional
Forester.  He has to determine that either an emergency situation
requires immediate, short-term relief, or that use of motorized equipment
in wilderness is the minimum tool necessary to achieve predator control. 
Pesticides can also be used.
 
Wilderness is suppoed to be an area "where man is a visitor . . . who
does not remain" and where human influence is "substantially
unnoticeable."  Designated wilderness is a uniquely American idea (as far
as I know), the heritage of people like Aldo Leopold, Olaus Murie and
Arthur Carhart.  No roads or motorized equipment is allowed, not even
mountain bikes.  Allowing motor vehicles into a wilderness for predator
control pretty much violates the whole idea of having areas where natural
ecological processes can continue undisturbed.  Certainly this language
could be used to allow aerial gunning of wolves in national forests, for
example.   

Audubon has a long history of opposing predator control when it is done
purely for the convenience of the livestock industry on public lands, and
we should not let predator control with motorized equipment in wilderness
or research natural areas occur without a fight.  There are ways to
control predation on site, without entering wilderness areas or RNAs -
guard dogs, herders, llamas, and more.

To view the full language of this proposal go to
www.epa.gov/fedrgstr/EPA-IMPACT/2006/June/Day-07/i8839.htm.    
Please send a letter to one of the addresses below, and tell the US
Forest Service and Wildlife Services that you opposed use of motor
vehicles and pesticides in wilderness for the purpose of predator
control.    In your letter you will need to reference the Forest Service
Manual, FSM 2323.33c, paragraphs 1-5 and FSM 2651.6.  The language on use
of motorized equipment in wilderness is in paragraph 3 of FSM 2323.33c.  
 
Addresses:  Written comments should go to:  Forest Service, USDA
                                                                    
Attn:  Director, Wilderness and Wild and Scenic Rivers Resources
                                                                     201
14th Street, SW
                                                                     
Washington, D.C.  20250
 
                        Email:  PDM at fs.fed.us
 
                        FAX:  202-205-1145
 
You can also submit comments by following the instructions at the Federal
e-Rulemaking portal, http://www.regulations.gov.
 
All comments are due by August 7th, 2006!!!!

We'd like to know how many people are sending letters, so please drop a
line to Polly Reetz, Conservation Chairman, at reetzfam at juno.com,
303-333-2164 and let her know after you've sent in comments. 
 
-------------- next part --------------
An HTML attachment was scrubbed...
URL: /pipermail/denveraudubon_denveraudubon.org/attachments/20060724/f355d009/attachment.html