In December 2012, NRDC and Sierra Club submitted comments in response to an Environmental Assessment (EA) issued by the federal agency Wildlife Services regarding its Gray Wolf Damage Management operations in Montana. We were encouraged by some aspects of the EA, such as Wildlife Services’ statements that it prefers using nonlethal over lethal methods to reduce livestock-predator conflicts, and the agency’s recognition that wolves have had significant positive ecological impacts, such as willow restoration in Yellowstone National Park. However, the EA’s analysis was inadequate, flawed, or absent altogether with respect to several important issues. For example:
- The EA failed to analyze (or even mention) Wildlife Services’ use of M-44 devices in Montana. M-44s eject lethal sodium cyanide poison into animals that trigger them. The EA did not discuss the environmental impacts of, or alternatives to, the use of this toxicant, which is known to adversely affect the environment and human health and safety. Nor did it acknowledge that, in 2010 alone, M-44s killed hundreds of non-target animals nationwide. (See Comments, pp. 7-8).
- The EA did not address the impacts of Wildlife Services’ use of lead ammunition on the environment, or suggest methods for mitigating those impacts. Cases of lead poisoning from the ingestion of lead ammunition have been documented for more than 100 species, including 59 species of terrestrial birds and many animals that Wildlife Services routinely shoots, including deer, squirrels, rabbits and coyotes. Even sublethal doses of lead can have devastating impacts, causing neurological and physiological impairment that hampers normal breeding and survival behaviors. (See Comments, pp. 14-16.)
- The EA dismissed many nonlethal predator-livestock conflict prevention methods as “generally ineffective,” but failed to cite many recent studies concluding the opposite. These include studies which describe the efficacy of electrified fladry (small strips of fabric or flags draped from fence rails or wire that flap in a breeze), various husbandry practices (such as bunching cows together), Radio Activated Guard technology, human presence (such as range riders), carcass-removal methods, and guard dogs. (See Comments, pp. 10-12.)
- The EA failed to acknowledge research indicating that wolf removals that disrupt a pack’s social structure can actually lead to increased livestock predation. For example, pack disintegration can cause young, inexperienced wolves and older wolves—who would otherwise be cared for by their pack—to turn to livestock depredations for food. (See Comments, pp. 8-9.)
- The EA failed to fully consider an alternative approach to conducting Wildlife Services’ operations in Montana which would require that all reasonable nonlethal methods be tried first, before resorting to lethal methods. The agency did not explain why it refuses to implement (or even discuss) such an alternative, despite its repeated statements that it “prefers” using nonlethal over lethal techniques. (See Comments, pp. 12-14.)
- The EA suggested there is a need to protect wildlife, livestock and people from transmission of diseases by wolves. However, there is very little evidence that wolves do or even can transmit brucellosis, that reducing wolf numbers will have any impact on reducing the environmental abundance of the tapeworm Echinococcus granulosus, or that wolves pose any higher risk of transmitting the parasite Neospora caninum than do any other canids, including domestic dogs. The EA failed to acknowledge that, to the contrary, wolves may play an important role in preventing disease transmission, by, for example, killing animals exhibiting symptoms of chronic wasting disease. (See Comments, pp. 2-3.)
NRDC’s comments addressed these and many other deficiencies in the EA. We also argued that, in accordance with the National Environmental Policy Act, Wildlife Services must complete a more detailed and comprehensive Environmental Impact Statement before it can continue with its Montana operations. Once Wildlife Services has reviewed our comments and announced how it intends to proceed, NRDC will weigh appropriate next steps. In the meantime, you can read more about NRDC’s Wildlife Services reform campaign here.