ADC- Action LETTERS NEEDED 11/30/00

--YOUR LETTERS NEEDED BY NOVEMBER 30, 2000

This alert contains six items:
1) What's At Stake
2) What You Can Do
3) Points to Make
4) Background
5) Sample Letter
6) Sender Information

Please forward this alert to interested parties.

---------------------------------------------------------------------------
WHAT’S AT STAKE

Each year, government-hired "aerial gunners" spend your tax dollars to shoot more than 23, 000 coyotes and other predators including wolves. This activity is done primarily in the guise of "livestock protection" for a few sheep and cattle ranchers and/or in a misguided effort to increase deer and elk populations.

Not only do your tax dollars pay for this slaughter of the public’s wildlife, but much of this activity takes place on your public lands with little or no public oversight. Each year Animal Damage Control/Wildlife Services (ADC) officials meet with public land managers--in secret--to plan how they will carry out this shameful subsidy.

These clandestine meetings are in direct violation of the spirit of democracy and numerous federal and state laws which mandate public participation in public lands management. According to US Council on Environmental Quality (CEQ) regulations, federal agencies must to the fullest extent possible, “Encourage and facilitate public involvement in decisions…” (40 CFR §1500.2(d)).

---------------------------------------------------------------------------
WHAT YOU CAN DO

It is with good reason that Animal Damage Control/Wildlife Services is preventing public participation in agency planning meetings. The simple fact is that they know that under public scrutiny this despicable activity would quickly end.

Please write to Michael Worthen, ADC Western Regional Director, and request that the public be allowed to participate in annual planning meetings between ADC and public land agencies such as the U.S. Forest Service and the Bureau of Land Management. Government wildlife killing programs will surely end if exposed to public scrutiny! Demand that these meetings be opened up to the public.

Please send your letters by November 30, 2000

Mail Comments to: Michael Worthen Western Regional Director USDA/APHIS/Wildlife Services 12345 W. Alameda Lakewood, CO 80228

EMAIL comments to: [log in to unmask] Note-If you comment by email, please include your postal (“snail mail”) address so your comments will be included in the public record.

Please also send a copy of your comments to

                        Wendy Keefover-Ring
                        Sinapu
                        2260 Baseline Road, Ste. 203
                        Boulder, CO 80302

Or EMAIL:       [log in to unmask]

---------------------------------------------------------------------------
POINTS TO MAKE
The public has a right and civil responsibility to be included. These meetings regard public lands and public wildlife. According to federal law, ADC must make a diligent effort to involve the public in such decisions.

Federal law further demands that highly controversial actions under go additional analysis and public scrutiny. Aerial gunning of wildlife is highly controversial--both the politics of it and the science. Americans strongly oppose it and little biological evidence exists that aerial gunning of coyotes has any effect on the number of livestock killed by predators.

As a taxpayer you have a right to be represented in these meetings since they are deciding how to spend scarce federal funds. Public land agencies are terribly under funded. While taxpayers are being charged increased user fees just to visit our public lands, millions of your tax dollars are paying to slaughter wildlife in these very places that you have to pay to visit!

Ask for a response. One of ADC's favorite tactics is to ignore dissent. Don't allow it! Be the squeaky wheel.

---------------------------------------------------------------------------
BACKGROUND

Federal agencies are required by law to involve the public in decisions affecting our public lands. CEQ regulations note that agencies shall, “Make diligent efforts to involve the public in preparing and implementing their NEPA procedures” (emphasis added, 40 CFR §1506.6(a)). Further, because its practices are highly controversial, ADC has additional legal obligations to facilitate meaningful public involvement in its planning processes. CEQ regulations further define one measure of intensity (which thereby increase the need for public involvement and additional analysis), as “[t]he degree to which the effects on the quality of the human environment are likely to be highly controversial” (40 C.F.R. §1508.27 (b)(4)). Controversial projects require careful consideration to ensure that public input is being duly and diligently considered and that factual disputes are resolved prior to making a decision or taking an action.

The American public has demonstrated broad support for wildlife protection and has demonstrated its disapproval of many of the methods used by ADC, such as denning (in which coyote pups are killed in their dens), cyanide baiting (which also regularly kills household pets), leg-hold trapping and aerial gunning of wildlife. Aerial gunning, is, according to ADC’s own analysis, seen by the public as one of the most inhumane manners in which to manage wild animals.

Moreover, ADC’s aerial gunning program has been demonstrated to be a significant threat to the humans that participate in those activities. Since 1989, ADC has had at least

·       17 aircraft accidents (1989 to present);
·       16 minor injuries;
·       5 serious injuries;
·       7 fatalities.

And since much of this activity occurs on public lands, where visitation and recreational use is increasing dramatically, aerial gunning represents and increased threat to innocent bystanders as well.

Furthermore, studies have demonstrated that lethal control of coyotes does not reduce livestock predation because of coyotes’ breeding habits and adaptability. In fact, the federal government has been killing coyotes since 1885, since which coyotes have actually expanded their range and population numbers. ADC lethal operations, in general, are a waste of taxpayer dollars.

Given ADC’s lethal wildlife operations, which represent attacks on the wildlife that Americans hold dear, as well as the use of killing tactics that have been widely critiqued by the public, it is increasingly apparent that ADC activities are out of rhythm with public sentiment. In addition, the threats to public safety and the waste of taxpayer monies that ADC operations represent further the need for public scrutiny of this agency’s operations. This discord between what ADC does, and what the public wants, can only be redressed if the public is included in ADC planning processes.

---------------------------------------------------------------------------
SAMPLE LETTER

This letter provides an example of how comments might incorporate the main points listed above. Remember, it is always best to write in your own words and illustrate your argument with your own experiences. Also, provide a little background on yourself and describe why you think protecting wildlife, fiscal responsibility and public involvement in public decisions are important.

Michael Worthen
Western Regional Director
USDA/APHIS/Wildlife Services
12345 W. Alameda
Lakewood, CO 80228

Dear Mr. Worthen:

        As a concerned American I am writing to urge you that the public be invited to and allowed to participate in the annual planning meetings between Animal Damage Control/Wildlife Services (ADC) and federal land agencies. I believe that ADC and land agencies are required by law to allow such participation.

According to Council on Environmental Quality (CEQ) regulations, agencies must to the fullest extent possible, “Encourage and facilitate public involvement in decisions…” (40 CFR §1500.2(d)). CEQ regulations further note that agencies shall, “Make diligent efforts to involve the public in preparing and implementing their NEPA procedures” (emphasis added, 40 CFR §1506.6(a)). In addition, because its practices are highly controversial, ADC has additional legal obligations to facilitate meaningful public involvement in its planning processes. CEQ regulations further define one measure of intensity (which thereby increase the need for public involvement and additional analysis), as “[t]he degree to which the effects on the quality of the human environment are likely to be highly controversial” (40 C.F.R. §1508.27 (b)(4)). Controversial projects require careful consideration to ensure that public input is being duly and diligently considered and that factual disputes are resolved prior to making a decision or taking an action.

        As you are no doubt aware, the aerial gunning of public wildlife (particularly on public lands) is not only politically controversial but scientifically as well. Studies have demonstrated that lethal control of coyotes does not reduce livestock predation because of coyotes’ breeding habits and adaptability. In fact, the federal government has been killing coyotes since 1885, since which coyotes have actually expanded their range and population numbers. ADC lethal operations, in general, are a waste of taxpayer dollars.

       As a taxpayer I find it disturbing that my hard earned money is subsidizing the slaughter of native wildlife to benefit private interests. It is even more troubling that much of this activity occurs on public lands, which belong to all Americans. As federal budgets for public lands continue to decline, and use increases, it is tragic that tax monies go to continue this shameful subsidy while basic needs on our public lands--such as fighting catastrophic fires--go under funded.

        For the reasons outlined above I urge you to open these planning meetings to the public. To do otherwise is a violation of your duty to serve the American public. Thank you for your consideration of my concerns. I eagerly await your response.

Sincerely,

Your name and address

---------------------------------------------------------------------------
SENDER

- For more information contact:
Wendy Keefover-Ring
Sinapu, 2260 Baseline Road, Ste. 203
Boulder, CO 80302
Phone: 303.447.8655
Fax: 303.447.8612