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Full text of "Animal damage control act of 1980 : hearings before the Subcommittee on Department Investigations, Oversight, and Research of the Committee on Agriculture, House of Representatives, Ninety-sixth Congress, second session, on H.R. 6725 and similar bills, April 16 and 17, 1980"

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r/lNlMAL DA VGE CONTROL ACT OF 1980 

HEARINGS 

BBFOBB THE 

SUBCOMMITTEE ON DEPABTMEOT 
INVESTIGATIONS, OVEBSIGHT, AND RESEABCH 

OF THE 

COMMITTEE 0]l^sA.6RICULTURE 
HOUSE OF REPRESENTATIVES 

NINETY-SIXTH COKGEESS 
SECOND SESSION 



H.R. 6725 and similar bills 



APBIL 16 AMD IT. ISSO 



Sirbl No. 96-BBB 




Printed for tbe ose of the Oommittee on Agrlcnltore 



C.B. OOTBBNIIBNT PRINTIMO OFFICSt 
WA8HINOTON : »80 



OS RECORD ONLK 



en % 



COMMITTEE ON AGRICULTURE 

THOMAS 8. FOLBT, Wasblngtoa, Chairman 

WILLIAM C. WAMPLER, Vlisliila 

Ranking Ulnorltv Member 
KEITB G. 8BBBLIUS, Kaoni 
PAUL FINDLEY, IUIdoIh 
STEVEN D. SYUM8, Idaho 
JAMES P. JOHNSON, Colorado 
EDWARD R. MADIQAN, nilnoli 
MAROARBT M. HECKLER, MauachuMttB 
JAMES M. JEFFORDS, Vermont 
RICHARD KELLY, Florida 
CHARLES E. QRASSLBY, Iowa 
TOM HAQEDORN, Mlnoegota 
E. THOMAS COLEMAN, MIbsouH 
RON MARLENBE. MOD tans 
LARRT J. HOPKINS, Keptucky 
WILLIAM ». THOMAS, California 



Viee Chairman 
WAI/TBa B. JONBS, Nortb Carollaa 
BD JONBS, TenDcaaee 
DAWSON MATHIS, Georgia 
GEORGE E. BROWN, JB., CalllorQla 
DAVID R. BOWEN, Mlastsslppl 
CHARLES ROSE, Norlli CarolliU 
FREDERICK W. RICHMOND, New York 
RICHARD NOLAN, Mlnneiota 
JIH WEAVER, OreiDD 
ALVIN BALDU8, Wliconilp 
TOM HARSIN, Iowa 
BERKLEY BEDELL, Iowa 
' GLENN ENGLISH, Oklahoma 
FLOYD J. FITHIAN, Indiana 
LEON E. PANETTA, CalUornla 
IKE SKELTON. Mlwourl 
JERRY HCCKABY, LouUlana 
DAN GLICKMAM. Xanm 
DANIEL K. AKAKA, Hawaii 
CHARLES WHITLEY, North Carolina 
TONY COELHO, Callfomta 
TOM DASCHLE, Soath DakoU 
KENT HANCE, Texai 
BERYL ANTHONY, Jb., Arkaniai 
CHARLES W. BTENHOLM, TeiM 

PKOriSSIONAI. Stit* 

FowLiI C. WlBT, Staff DirtBtor 

; ROBIST M. Boa, CMtt Counatt 

John B. Hooah, Counsel 

IT S. Kbahib, Sptclal Oouiutl 



^^'4' 



SuBCOMum^ onUepabtuent Invebtioatioks, Ovixsiokt, ahd Rebeab(th 

B 0*^ OARZA, Texu, Chairman 
GEORGE B. BROWN, Ja., CalUondft WIIXIAH C. WAMPLER, Virginia 

FLOYD J. FITHIAN, Indiana MARGARET M. HBCKLBR, Manaelin*etU 

1KB SKELTON, MlnoaH . CHABLE8 B. QRA8BLBY, Iowa 

DAN GUCKllAN, Sum* 
GLENN ENGLISH, Oklahoma 

IH) 



D,g,tze:Jb.GOOg[e 



CONTENTS 



H.R, 6725, a bill to require the Secretary of the Interior, in cooperation 
with the Secretary of Agriculture, to implement certain requirements f^n 
relating to animal damage control, and for other purposes 3 

de la Garza, Hon. E, a Representative in Congress from the State of Texas, 

opening remarks 1 

Wampler, Hon. William C, a Representative in Congress from the State 



W ampler, 
of Virgil 



I, opening remarlis- . 



BuTOn, Jim, III, representing National Cattlemen's Association, Public 

iWda Council, and National Grange 242 

Boothby, Charles L., executive secretary. National Association of Conser- 
vation Districts 101 

Bowns, James E., range ecologist, Utah State University, Logan, and 

Southern Utah State College, Cedar City 102 

Brown, Reagan V., commissioner of agriculture. State of Texas, repre- 
senting Governor Clements 83 

Cargile, John, president, Texas and Southwestern Cattle Raisers 

Association 211 

Connolly, Guy E., wildlife biologist. Twin Falls, Idaho, Research Station, 

Denver Wildlife Research Cent«r, U.S. Fish and WildUfe Service 227 

Cutler, M. Rupert, Assistant Secretary, Natural Resources and Environ- 
ment, U.S. Department of Agriculture 42 

Douglass, Gus R,, commissioner, West Virginia Department of Agriculture. 180 

Flitner, David, president, Wyoming Farm Bureau 93 

Gillmor, Stephen T., Utah-Idaho Farmers Union 128 

Grandy, John W., executive vice president, Defenders of Wildlife 140 

Hansen, Hon. George, a Representative in Congress from the State of 

Idaho ._ _ 12 

HerbBt, Robert L., Assistant Secretary, Fish and Wildlife and Parks, U.S. 

Department of the Interior 44 

Howard, Charles L., Jr., cattle, pecan, and goat farmer. Meridian, Tex — 206 
Jellinek, Steven D., Assistant Administrator, Pesticides and Toxic Sub- 
stances, Environmental Protection Agency 47 

Knowlton, Frederick F., department of wildlife science, Utah State 

University _ 219 

Leath, Hon. Marvin, a Representative in Congress from the State of Texas. 21 

Lipscomb, Fran, Society for Animal Protective Legislation 195 

LoefRer, Hon. Tom, a Representative in Congress from the State of Texas. 16 

Marlenee, Hon. Ron, a Representative in Congress from the State of 

Montana 68 

Mullins, Robert J., assistant director, legislative services. National Fanners 

Union 127 

Noh, Laird, chairman, environmental committee, National Wool Growers 

Association and Utah Wool Growers 114 

Perkins, Marguerite, Humane Society of the United States 188 

Stenholm, Hon. Charles W., a Representative in Congress from the State 

of Texas _ _ __ 40 

Wade, Dale, Texas Agricultural Extension Service, Texas A. & M. Uni- 
versity System __- 222 

Wardlaw, Martin, president, Texas Sheep and Goat Riusers' Association.. 238 
(in) 



56 T 353211 

9/98 31150-37 '"le i^ 

D,g,tze:Jb.GOOg[e 



Material Subuitted 

Armeatrout, Dr. Dede, National Audubon Society, prepared st&tement 

Cheney, Hon. Dick, a Representative in Congress from the State of 
Wyoming, prepared statement 

Creer, Dr. Kenoeth B., commissioner, Utah State Department of Agrj' 
culture, prepared statement . 

Cruickshank, Stewart, president, Idaho Wool Growers Association, letter of 
Dec. 20, 1979, to Hon. Steven D. Symms, a Representative in Congress 
from the State of Idaho 

Dennis, W. Bert, Texas Animal Damage Control Association, Inc., pre- 
pared statement 

Frank, Floyd W., dean, veterinary medicine, University of Idaho, letter of 
March 31, 1980, to Hon. Steven D. Symms, a Representative in Con- 
gress from the State of Idaho 

Greenwalt, Lynn A., Director, U.S. Pish and Wildlife Service, U.S. De- 
partment of the Interior, letter of Sept. 2S, 1979, to Robert L. Herbst, 
Assistant Secretary, Fish and Wildlife and Parks 

Kaz^ Hon. Abraham, Jr., a Representative in Congress from the State 
of Texas, prepared statement __ 

Kimball, 'niomas L., National Wildlife Federation, letter of Apr. 16, 1980, 
to Hon. E dela Garza..- _ 

King, Bruce, Governor, State of New Mexico, prepared statement 

Mogensen, Mike, Idaho Cattlemen's Association, Boise, Idaho, letter of 
Apr. 8, 1980, to Hon. George Hansen 

Noh, Laird, cochair, the Sheep Producer/ Environmentalist Committee, 
letter of March 10, 1980, to Lynn A. Greenwalt, Director, Fish and 
Wildlife Service, U.S. Department of the Interior 

Poole, Daniel A., Wildlife Management Institute, letter of Apr. 10, 1980, 
to Hon. Edela Garaa 

Symms, Hon. Steven D., a Representative in Congress from the State of 
Idaho, prepared statement 

TuUy, Robert J., Animal Damage Control Policy Committee, International 
Association of Fish and Wildlife Agencies, prepared statement 

Zaunbrecher, Dusty, legislative counsel, International Association of Fish 
and Wildlife Agencies, letter of May 2, 1980 



D,g,tze:Jb.GOOg[e 



ANIMAL DAMAGE CONTROL ACT OF 1980 



wednsbdat, apbil 16, 1980 

House of Repbesentativeb, 
Subcommittee on Department 
Invebtiqations, Ovebsioht, and Research 

OF THE Committee on Agkiculture, 

Waahington, D.C. 
The subcommittee met, pursuant to notice, at 10 a.m., in room 
1302, Longworth House Office Building, Hon. E de la Garza (chairman 
of the subcommittee) presiding. 
Present: Representatives Skelton, Wampler, and Grassley. 
Also present: Representative Symms of the full committee. 
Staff present: Fowler C West, staff director; Robert M, Bor, chief 
counsel; John Hogan, counsel; Gary Norton, associate counsel; 
Glaida Temple, clerk; Bernard Brenner, Bert Pena, Mario Castillo, 
Jerry Jorgensen, Thomas E. Adams, and John Bailey. 

OPENINa STATEHENT OP HON. £ de la GABZA, A SEPBESENTATITE 
or CONGBESS 7R0H THE STATE 07 TEXAS 

Mr. DE i/A Gabza. The subcommittee will be in order. 

The Subcommittee on Department Investigations, Oversight, fmd 
Research meets today in public hearing to consider H.R. 6725, the 
Animal Damage Control Act, and on other similar legislation, al- 
though it is not listed. 

Because of the ui¥;ency of the situation and the number of witnesses 
we have today and tomorrow, I will fot^o any opening statement 
except to say that what we hope to do here is to brii^ some of the 
issues related to this problem mto focus and to stop the emotional 
polarizing effect that seems to be getting worse in relation to this 
situation. 

I would like to repeat what a great statesman once said : "Polanzatkm 
generates only heat, never any hght." Hopefully, we will bring some 
ueht to bear on this problem, which is a very senous one to a segment 
of the food industry as well as to those of us who have a great interest 
in conservation which includes the preservation of all species on this 
planet. 

Unfortunately, man is the only species that does not forage for 
itself for sustenance and one of the main items of his diet is red meat. 
The source of supply of that part of his diet is of great importance. 
Those that supply it have a very serious problem that runs, con- 
ceivably, into milnons of dollars. 

This is a modest, himible attempt by several of the Members of 
Congress to bring a semblance of sanity to what seems to have gone 
astray. Hopefully, with men and women of good will, we will arrive 

(1) 



D,g,tze:Jb.GOOg[e 



1 (5) use preventive eontrol teehniques to manage 

2 offending predator populations. 

3 (b) The Secretary of the Interior, in cooperation with 

4 the Secretary of Agriculture, shall estabhsh an ad hoc com- 

5 mittee to review the activities carried out by the Secretary of 

6 the Interior relating to animal daoiage control. Such commit- 

7 tee shall be composed of members representing agricultural 

8 and other affected interests. The review of such activities 

9 shall be conducted every two years. The committee shall — 

10 (1) assess the extent to which animal damage con- 

11 trol activities are in compHance with the requirements 

12 of this Act; 

13 (2) assess the success of the program in reducing 

14 an'nial damage; and 

15 (3) make recommendatioaa to the Secretary of the 

16 Interior and the Secretary of Agriculture relating to 

17 measures needed to make such activities more effec- 

18 five. 

19 Sec. 4. The Secretary of the Interior and the Secretary 

20 (rf Agriculture shall submit to the Congress, not later than 

21 one year after the date c^ the enactment of this Act, and 

22 annually thereafter, a joint report relating to the development 

23 and implementation of the animal damage control program 

24 provided for in section 3. 



D,g,tze:Jb.GOOg[e 



96th CONGRESS YT n ^^Of 

2D SESSION |-1,K., O/^D 

To require the Secretary of the Interior, b cooperation with the Secretuy of 
Agriculture, to implement cerUun requirements relating to uiiiaal dun&ge 
control, and for other purpoaea. 



m THE HOUSE OP REPRESENTATIVES 

Uabgh 6, 1980 
i/A Oabza (for himself and Hi. JjOEFFLBb) introduced the foUowtog bill; 
which wu referred to the Conmiittee on Agriculture 



A BILL 

To require the Secret&ry of the Interior, in cooperation with the 
Secretary of Agriculture, to implement certain requirements 
relating to animal damage control, and for other purposes. 

1 Be it enacted by the Senate and House of Repreaenta- 

2 lives of the United States of America tn Congress aaaembhd, 

3 That this Act may be cited as the "Animal Damage Control 

4 Act of 1980". ^ 

5 Sec. 2. The Congress finds that— 

6 (1) producers of livestock provide a valuable 

7 source of food and goods to the American people; 



D,g,tze:Jb.GOOg[e 



1 {2) despite efforts to reduce damage caused by 

2 predators of livestock, such producers continue to 

3 suffer significant losses each year to their livestock 

4 herds as a result of predator attacks; 

5 (3) livestock producers have cooperated extensive- 

6 ly with Federal departments and agencies in develop- 

7 ing and implementing reasonable animal damage con- 

8 trol measures; and 

9 (4) in order to reduce significantly the annual 

10 losses that livestock producers suffer as a result of 

11 predator attacks, the Secretary of Agriculture and the 

12 Secretary of the Interior should jointly develop and 

13 carry out a bahmced animal damage control program 

14 that effectively utiUzes both lethal and nonletbal con- 

15 trol measures. 

16 Sec. 3. (a) The Secretary of the Interior shall conduct a 

17 program relating to animal damage control in cooperation 

18 with the Secretary of Agriculture and, in carrying out such 

19 program, shall — 

20 (1) use, and pennit the use of, effective lethal aod 

21 nonletbal animal control devices, methods, and chemi- 

22 cal toxicants; 

23 (2) undertake extended research activities relating 

24 to chemical toxicants (including compound 1080) and 



D,g,tze:Jb.GOOg[e 



1 (D) Bnares. 

2 (2) Undertake extended research activities relating 

3 to chemical toxicants, including compound 1080, and 

4 emphasize selective and environmentally preferred 

5 lethal and nonlethal toxicants. Such reseB,rch shaJl 

6 analyze — 

7 (A) the efficiency of such toxicants; 

8 (B) the effects of such toxicants on the envi- 

9 ronment and on animals other than the offending 

10 species; and 

11 (O the advantages of certain toxicants. 

12 Such research efforts shall be directed toward the 

13 development and use of effective and environmentally 

14 acceptable toxicants. 

15 (3) Use and permit the use of toxicants, including 

16 compound 1080, until such time as a more suitable 

17 selective toxicant is developed. 

18 (4) Undertake applied ffeld research relating to 

19 nonlethal animal damage control techniques and the 

20 effectiveness of economiciUly feasible husbandry prac- 

21 tices in reducing livestock losses under various ffeld 

22 conditions. Such research shall analyze: — 

23 (A) the efficiency and cost of such techniques 

24 and practices; 



D,g,tze:Jb.GOOg[e 



10 

4 

1 (B) the effects of such techniques and prac- 

2 tices on the environment and on animala other 

3 than the offending species; and 

4 (C) the advantages of certain techniques and 

5 practices. 

6 (5) Use preventive control techniques to manage 

7 offending predator populations. 

8 (6) Establish an ad hoc committee to review the 

9 activities carried out by the Secretaiy of the Interior 

10 relating to animal damage control. Such committ«e 

1 1 shall be composed of members representing agricultural 

12 and other affected interests. The review of such activi- 

13 ties shall be conducted every two years. The commit- 

14 tee shall — 

15 (A) assess the extent to which animal 

16 damage control activities are in compliance with 

17 the requirements of this Act; 

18 (B) assess the success of the program in re- 

19 ducing animal damage; and 

20 (C) make recommendations to the Secretary 

21 of the Interior and the Secretary of Agriculture 

22 relating to measures needed to make such activi- 

23 lies more effective. 

24 Sec. 4. The Secretary of the Interior and the Secretary 

25 of Agriculture shall submit to Congress, not later than one 



D,g,tze:Jb.GOOg[e 



11 



5 

1 year after the date of the enactment of this Act, and annually 

2 thereafter, a joint report relating to the development and im- 

3 plementation of the animal damage control program provided 

4 for in section 3. 



D,g,tze:Jb.GOOg[e 



12 

Mr. DB LA Garza. I have one final word. This is not an adversary 
hearing or procedure. This is hopefully a positive approach to arriving at 
some solution to the prohlem. 

This morning we have several Members of Coi^ress who are co- 
authors of the l^islation. We will first call upon Hon. George Hansen, 
a Member of Congress from Idaho. 

STATEMENT OF HON. aEOROE HANSEN, A BEPBESENTATIVE IN 
CONOBESS FEOK THE STATE OF IDAHO 

Mr. Hansen. Thank you, Mr. Chairman. I would like to congratu- 
late you on the timely introduction and consideration of this bill, which 
is essential to the well-being of the domestic livestock industry. 

Mr. Chairman, I would also like to introduce, from my State, Mr. 
Laird Nob, representing the Idaho and National Wool Growers 
Association, ana ask if he would please stand. 

[Mr. Noh stands for recognition.] 

Mr. Noh has been a long-time member of this group and is p 

iblem 



involved in wool growing. He understands the problem very well and, 
I believe, will provide most helpful information when he testifies later. 

Predators caused $60 million worth of damage in 16 Western States 
in 1977 alone. For that reason among others, Mr. Chairman, I have 
joined you and other concerned members of tbi^ committee in sponsor- 
ing this legislation to help farmers and ranchers protect their crops 
and livestock. 

The Animal Damage Control Act of 1980 provides for effective and 
responsible methods to control predators and to protect the economic 
well-being of our rural commumties and the food supply of the Nation. 

Predation is not just a loss to the agricultural community. Depart- 
ment of Agriculture studies show that the American consumer ulti- 
mately suffers the most signiScant economic impact through higher 
prices. 

The bill was introduced to offset a policy statement by Secretary of 
the Interior Cecil Andrus which poses a severe threat to agriculture by 
radically altering and deemphasimig Federal predator control pro- 
grams. I feel strongly that the Andrus policy is m direct conflict with 
both current Federal law and the wishes of Congress as expressed 
through annual increases in funds for predator control efforts. 

We must seriously question a pohcy, Mr. Chairman, which is based 
in such statements as : 

Before selective lethal control could begin on Federal lands, a threshold of 5 to 
lOpercent of verified predator losses in particular herds should be reached. Lethal 
predator control should be conducted onljr within the immediate vicinity of live- 
stock losses. No buffer sone clearance of predators would or should be permitted. 

This committee has information available and will be receiving 
further testimony regarding details of predator losses, chemical sub- 
stance evaluations, and other pertinent information. I will therefore 
not attempt to review such details with you today. 

I have, however, contacted several parties in Idaho who have been 
impacted by such Federal policy proposals including the Idaho Cattle- 
men's Association. I respectfully request that the comments of the 
organization be made part of the record. 

Further statements will also be provided by representatives of this 
organization who will be appearing before this committee. 



D,g,tze:Jb.GOOg[e 



13 

Again, this committee is to be commended for its past efforts to 
strengthen the agricultural economy and I hope needed l^islation can 
be devised to give necessary relief to the American livestock industry. 

Mr. Chairman, as a former member of this committee, I appreciate 
veiy much your indulgence. Thank you. 

Mr. DE LA Garza. Without objection, if you will supply for the 
record the statements which you wish to submit on benali of your 
constituents, they will be included in the record at this point. We 
appreciate them. 

Mr. Hansen. Thank you. 

[The attachment referred to by Mr. Hansen follows :] 



D,g,tze:Jb.GOOg[e 



IDAHO CATTLEMEN'S ASSOCIATION 




Congressiui) Caoiga Buawi 
1125 Longworth Building 
Hashlngton, H.C. 20515 



sddreBBfng CDQpBrativft Aniiul Dana^ft i 
tariu of Intarioc and Kgrlmiltun. 

The pmvliloni of Uils laglalatlon ara saaentlal In aalntainlng a 
viable piadltnr contiral policy foe Uia livestock Induetry. As yoB know, 
cattlB and ahcep prodocera have uorkad cooperatively for many yaara ulai 
the O.S. Fish and Wildlife Seivlca te develop an affective preditor control 
program. 

However, recent policy changca by the Interior Department have Ignored 
the Input frOB these producers and ■■ • result, outlawed the uaa of 'lethal' 



This legislation would provid 




practices. 




He fully support this legisla 


Ion and offer any posslbl 


the future on this Imue. Ha also 


support the woolgrewers 1 


to oalntain an effective preditor <: 


■ontrol piogrn. 


Please let us know If we can a 


stlst you farther. 


Also, thanJt you very nidi for 


co-signing Congresaiui. Syi 


eollegue letter on the BcH axtenBle 


« of comnt period. 



n^AuiS*-,^ 



K vi H, s Env. Affair* Com. 

2120 AIRPOnT WAV • BOISE. IDAHO B3T05 • PHONE (208) 344 » 



D,g,tze:Jb.GOOg[e 



Predator lotrM 



Tear 


(1000) ' 


bv =I.f«c'l 


: LaBlr 


Lubs 


fclllBd . 

£atsri if 


TlluB of 




<150C) : {-) 


"(1000) 


= «) 


fSlOOO) 


1958 


■ 1109 


. 8 ! ...7 




30 


1 3.0 


889 


19SS 


1170 


8 ! .7 


: 99? 


. 29 


1 2.9 


694 


1960. 


1153 


9 .1 .8 


: 1010 


33 


! 3.3 


643 


1961 


1096 _ 


8 "! .7 


: 99= 


29 


5 2.9 : 


— . Ml 


196Z 


10*1 


,12 : 1.1 ■ 


1 .917 


41 


!">4.s ;i 




. 196) 


lOOS , 


; 8 : .8 


88! 


30 


1 3.4 i 


"•- . *" .■ 


1964 


_ 93r _ 


IZ' ; 1.3 


761 


.. 45 


: 5.9 ! 


1098 


1965 


908 ■ 


9 i ?.0 


7S1 


'32 


I 4.3 i 


914 


1966 


859 


■ -12 : 1.4 


725 


43 


; S.9 1 


1344 


1967 


844 


8 I .9 


. Joe 


29 


: 4.1 i 


916 


1968 


B44 


.9' i 1.1 


688 


.33 


i 4.8 i 


.U70 


1969 


870 


9 ! 1.0 


672 i 


3* 


I 5.1 : 


1410 


1970 


8M. 


a ;l 1.0 


653 : 


30 


'i 4.6 t 


1153 


1971 


823 


15 ': 1.8 


670 : 


54 


■ 8.1 ! 


2041 


1971 


780 


11. t l.S 


644 I 


43 


6.7 : 


1763 


1973 


707 


11 1 1.6 


596 : 


■• 39 


«.S i 


1919 


1974 


684 


. 10 ! 1.5 


6*S 1 


37 


5.7 ; 


1861 


1975 


595 


12 ! 2.0 


56C ; 


.43 


7.7 \ 


. ,I«3 


1976 


S3g 


7 I 1.3 


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26 


4.9 i 


, 1462 


1977 


503 


9 ! 1.8 


491 i 


32 


6.5 : 


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1978 ' 


' 536 


7 ': 1.3 


471 ! 


". 


6.4 1 


J192 



t l(id>( killed by prcdetori betoi 



D,g,tze:Jb.GOOg[e 



16 

Mr. DE LA Garza. The next witness is Hon. Tom Loeffler, a Mem- 
ber of Congress from Texas, who is a coauthor, and I might say a lead 
coauthor. He has been very helpful in this endeavor. 

Mr. Iioeffler is one of the bright new stars of the new Members we 
have in the Coi^jess from Texas. We are very happy to have you here 
today. 

SIATEHEirr OF HON. TOM LOEFFLER, A REPRESENTATIVE IN 
CONGRESS FROM THE STATE OF TEZAS 

Mr. LoBFFLSR. Thank you, Mr. Chairman. 

Mr. Chairman and members of the subcommittee, I appreciate the 
opportunity to appear before you today to discuss the future of the 
animal damage control program. 

On March 6 1 was pleased to join with the distinguished chairman of 
this subcommittee in introducing H.R. 6725, the Animal Damage Con- 
trol Act of 1980, which I hope will provide an opportunity for us to 
review this critical program and to revise and strengthen a law written 
in the 1930's. 

Mr. Chairman, two aspects of the 1931 Predatory Animal and 
Rodent Control Act are noteworthy. Not only does the act require that 
the Federal program control predation in order to protect this Nation's 
livestock, it expressly authorizes such activities on privately owned 
lands as well. The impact, then, of Federal predator control policy is 
felt on farms and ranches nationwide, not merely on those lands pres- 
ently administered by the Department of the Interior. 

Because the Secretary has recently revised the Federal program in 
what I feel is a strongly detrimental manner, I firmly believe that it 
is imperative that we take appropriate steps to insure the protection 
of the country's food and fiber resources from unwarranted losses due 
to predatory animals. 

Livestock loss as a result of predator damage has been a problem of 
long standii^ and one of increasii^ly severe proportions recently. 

In 1977 the Nation's sheep and goat industry lost an estunated 
$69 million — 17 percent of the industry's gross income for the 
year — due to predation. Predators killed more than 1.2 million head of 
sheep and goats during 1977 and because of these losses some 290,000 
tons of red meat never made its way to American tables. 

In addition, the U.S. Department of Agriculture's Economic Statis- 
tics and Cooperative Service found that m 1978 American consumers 
were deprived of more than $16 million worth of beef because of calves 
lost to predator attacks. 

Texas, as you know, is the leading sheep- and goat-producing State 
in the country. Yet their numbers have continually declined duri^ 
the past three decades, in large part due to predator losses resulting in 
this Nation having to rely on greater and greater quantities of imported 
products. 

In 1978 alone predator attacks were responsible for 58 percent of all 
losses to sheep and lambs, compared to 25 percent in 1967, and a stag- 
gering 72 percent of goat and kid losses in Texas. In each case, coyotes 
were the largest single cause of death to livestock from all causes in the 
State of Texas in 1978. 



D,g,tze:Jb.GOOg[e 



17 

The Texas and Southwest Cattle Raisers Association recently 
estimated that cumulatiTe losses to predators over the last 12 years 
have resulted in the loss of more than 250 million pounds of beefT 

It is obvious from these statistics that predators are not in conflict 
with livestock. Rather, they are in fact in direct competition with man 
for food. Furthermore, over and above this tremendous loss of available 
food and fiber, these same studies show that the American consumer 
ultimately suffers the most significant economic impact through higher 
prices for agricultural goods. 

The Federal predator control program, once firmly based on clear 
statutory authority, has more recently come to be guided by policies 
which are outlined in conferences, speeches, letters, and memoranda 
rather thfui in new legislation or even in bindii^ administrative 
regulations. 

Furthermore, much of the animal damage control policy promul- 
gated during the last several years, including major portions of recent 
announcements, has been directed by the results of premature evalua- 
tions of incomplete and biased data compiled during the late 1960's 
and earlv 1970's. Unfortunately, reconunedations from these evalua- 
tions lea to executive decisions to suspend the use of toxicants in 
1972 and to severely restrict most if not all of the lethal control 
measures then in use. 

Since 1972 the Federal Government has continued to exercise its 
power to regulate the use of Federal lands as a means of r^;ulating 
predator control activities. 

Also, additional authorities enacted into law were used in 1972 to 
cancel the registration of some of the most effective and widely used 
toxic substances in predator control. The fact that sodium cyanide 
has been given a clean bill of health since that time underscores the 
lack of scientific data available to the decisionmakers in 1972, in 
addition to reinforcit^ recent statements that compound 1080 remains 
restricted for purely political rather than scientific or practical reasons 
after more than 8 years of intensive research. 

Other than opposition to the use of chemical toxicants and the utili- 
zation of lethal control methods in the conduct of predator control 
programs, the major criticism of these programs has oeen the lack of 
scientific data on the extent of livestocK losses due to predators and 
the ecoli^cal effects of various control methods. 

However, despite efforts to block such research, until recently on- 
going efforts to develop scientific data have been conducted somewhat 
free of unnecessary and unreasonable governmental intervention. 
Until a short time ago the U.S. Fish and Wildlife Service, in coopera- 
tion with EPA, was conducting a comprehensive examination of 
compound 1080, proven to be uie most responsible, effective, and 
selective tool known in predator control, particularly when used in 
the toxic collar. 

The Secretary's November decision to halt further research on 1080, 
notwithstanding recommendations by virtually all professional animal 
damage control researchers, in my opinion points out a lack of dedica- 
tion or interest in assuring an objective evaluation of all of the facts 
surrounding this controversial issue, and a deeper lack of commit- 
ment by the Department of the Interior toward msuring the develop- 
ment of an adequate predator damage management program. 



D,g,tze:Jb.GOOg[e 



Ifi 

I find it further incomprehensible that the Department intends to 
implement a policy which emphasizes nonlethal preventive metiiods 
when the clear intent of the 1931 act was to control and eliminate 
predator damage of livestock. Moreover, in limiting existing control 
techniques, already severely restricted by past ana present Interior 
Department policies, to instances when "unacceptably high losses have 
been documented," the Department exhibits A clear disregard for the 
current capability to document such losses. 

In my view, the losses which livestock producers are presently 
suffering due to the lack of responsible and effective predator control 
methods are already "unacceptably hi^h losses." 

All of us are keenly aware of the critical importance of maintaining 
a careful balance between livestock and wildlife. A rancher's very 
livelihood depends upon the preservation of our ecological system. By 
allowing the use of proven, effective, and responsible means to control 
predator damage, while insuring research and development of other 
viable alternatives, I strongly believe that this legislation reflects the 
desire of concerned agricultural and environmental groups to resolve 
this critical problem. 

I uT^e the subcommittee to carefully and objectively review the 
facts surrounding this controversial issue. I will work witii you in any 
WW that I can to insure the development of a sound ADC policy. 

Thank you, Mr. Chairman, for the opportunity to appear oefore 
you today and for the pleasure of working with you in the introduction 
of the legislation that we are considering today. 

[Attaobments to the statement follow^ 



D,g,tze:Jb.GOOg[e 





D,B,i..ab,Google 





Mr. DE LA Garza. Thank you, Mr. Loeffler. 

We appreciate all of your cooperation and your testimony today. 

The next witness is the Honorable Marvin Leath, a Member of 
Confess from Texas. We welcome you before this subconmuttee, 
Mr. Leath. 

Mr. I<eath replaced, with his blessii^, the former chairman of this 
committee, Mr. Bob Poage from Texas. 



D,g,tze:Jb.GOOg[e 



STATEMENT 07 HON. HARYTE LEATH, A EEFSE8ENTATIVE IN 
CONOBESS FBOH TEE STATE OF TEXAS 

Mr. Lbath. Mr. Chairman, I appreciate beii^ here very much. 

I want to inform you that just immediately prior to comii^ over 
here I had the opportunity to visit with Bob Foage on the phone. I 
told him that I was about to come over here to talk about coyotes. 
I feel sure that your chair will begin to vibrate any minute because 
we will certainly feel his spirit and presence here this moming because 
this was indeed a subject that was dear to his heart. 

Mr. Chairman and members of the committee, it is certiunly my 
pleasure to be before you today to talk about our agricultural pro- 
grams and spec^cally the predator control program. 

As you know, all sectors of the agricultural industry from producers 
to consumers are financially hard pressed. On one hand we are seeing 
rapidly rising prices to the consumer. Food prices rose 10.9 percent 
in 1079. On the other side we see less income to the producer. Form 
income roee only 6 percent while farm production costs for ranchers 
increased 12.6 percent in 1979. 

Therefore, it is all important that we in Government follow through 
with our congressional mandate of, in this instance, ei^aging m 
predator control. 

I hasten to point out that if we would but bUow the producer the 
opportunity, he could very easily take care of his own problems. 
However, as you are aware, the Department of the Interior has 
severely restricted or eliminated the most efficient and cheapest con- 
trols known to the Kvestock producers. 

l^UB can be seen most recently in Secretary of the Interior Cecil 
Andrus' November 1979 announcement of continued restrictive use 
of M-44 and aerial hunting and of stressing the increased use of non- 
lethal methods of control. 

Mr. Chairman, to me this makes absolutely no sense, given the 
costly and in most cases ineffective means Secretary Andrus left to 
ranchers. What the Secretary of the Interior did was to take away 
the right of the hvestock producer to defend his property and his 
Uvelihood. 

For instance, in my home State of Texas, it is estimated that 
Uvestock producers suffered $13 million in livestock losses due to 

Kredators m 197S. These are dollars that the rancher can ill afford to 
>se, as I noted earlier in niy testimony. 

Mr. Chairman, as I understand the intent of this subcommittee, 
you are holding these hearings to help develop a balanced animal 
damage control program effectively utilizing lethal and nonlethal con- 
trol measures. Of course, I am very much in favor of these objectives. 

At this time, I would like to include in the record a copy of a report 
prepared by Professor Ernest Kun on the toxicity of one effective 
preaacide, compound lOSO, or sodium monofluoroacetate. As you are 
aware, 1080 is used in conjunction with collared sheep in order to help 
control coyote kills of sheep and goats. 

A constituent of mine, Mr. Qiarles Howard, of Meridian, Tex,, is 
currently engaged in a contract with the Department of the Interior 
to study the effectiveness of the toxic collar and 1080. To date the 
results nave been positive and I feel they will continue to be so. The 
toxic collar appears to be effective and is very restrictive. Mr. Howard 



D,g,tze:Jb.GOOg[e 



will be giviiig testimony tomorrow in greater detail on his results so I 
will not go into the specifics at this time. 

I would just like to say that I am very excited over his results so far 
as they point toward a balanced control of coyote predation. Certainly, 
I hope, and I know that you will give him and his test data close 
attention. 

In addition, Mr. Chairmui, I would like to include for the record a 
copy of a Congressional Research Service paper that ex^ains in 
layman's lai^uage «^at Dr. Kun's findings mean. Briefly, Dr. Kun 
found that the concern of many that the predacide 1080, a stiychnine- 
based poison, posed a secondary poison hazard was nonexistent. If 
Dr. Kun is correct, then 1080 may very well be the answer to many of 
our producers' problems. I would imagine that further testii^ is 
necessary to see if Dr. Kun's findings can be duplicated. 

This IS where the proposed legislation, H.R. 6725, is all important 
as it will give legislative direction to the Interior Department con- 
cerning vi^le, readily available control measures. 

Mr. Chairman, I want to thank you again for holding these hearings. 
You are to be commended for havmg the foresight for rec(^:niziiig the 
problems faced by the agricultural sector. I have long studiea this 
issue and have found our current programs lacking. This is exactly 
why I have joined with you in cosponsorship of H.R, 6725. 

My piedecessor, the Honorable Bob Poage, served with dignity on 
this committee and was committed to responsive responsible predator 
control programs. This legislation and the leadership you are providing 
are in keeping with his eariier work. 

Again, Mr. Chairman, I want to thank you for this opportunity to 
appear before you. 

[The attachments referred to follow:] 



D,g,tze:Jb.GOOg[e 



Suli^tt*d.iy ErnMt -Kun, rrsfuHI bt Exp. Pba»aulB(|i, 
' IfHlwliIir >■>' lle*1vrleil Uiil«»ltf ol Callfotnta 
' St •» riaKlic*; iBii* tUf 101. Sh' FrawslaeB MU3...- 



■jikireunJtnd purpoM of watk . The luiMlwIia at ftf' dalaDnd BDlaculat 
■ aachaiilaiH et tDitclCir ttf r-apatat* pelaa'nliv i» 'a.prtrcqui.ii. to tl» 
cprcac^ ■nluallonct public >>aallli haiairda a* ytll ■■ uxfulnaia or (Ml 
h.(|t«lT I*"" rodine.cMa aO»), A* ahiw br thla tnvciiit.tDi (Wlcculii 
'rha~«lai7 1« l>t-l««i »W.' Iha precl.a •<><). oE aulon of th. to.ii: 
wtibnlltt at tha iwB-ton'tT pifcunor f-a^utt uhich i. (-j .rvil.roHuoto - 
• ijtrlc acM. li adll at an aarlr acaia at aclaatllU'/davilDposnt , ind wijt 
nr-jh. taftUr Inlor-otlon In ih). are. 1. In icrlo.n ito^bi . It iHceaaarllr 
iollMi th*t *p» pr.«nil)r ulnt.Inad .ihltta., [o-al vl« in thi. araa 
tiaatd an lanaia] taxtbask Infanutlaa (un* ih. cUk of b.tni r,.°..l. Inu^t . 
Dat eaontcclon vlcK Dt d'. Baliar raiultxl fa • rilatlnlT >horl pcrlvd Df 

Uia4 b)>-Ehti Invaittiatpr 10 yaaia afs Thla.yotk Ii procrxlr <on[lniMd ei 

ippin<l..»picti ol thU woik. Untotiunj.,!, *• tacofnlaad trim Bi. Bal>«'i 
.(•cant iittac, auppDct tl thla will la avu ^ahlhttad by adBlniatratlvc di-el. 

iMa'Miaaiy raparc untalaat 



actisa la ■otcly daa Co Ici •paclftc i^nvarilon .»' t-Vaky thiol linrselt etc acid 
' ini'j fi\-m, ■• d«*«lBrW ■ IpMltle aniyuttc'aatbed.Ial (ha aynclnaU at 



D,g,tze:Jb.GOOg[e 



l*C-lib*Il«il (-jairthielluonclCTlc leld that tt to b* mad m 
ualyclcal verk cMcaniad vlch thi dttaniutlan ef th* ia irlw ci 
leiu of (-}aiychTafltwiecltrlc acid In Inhally polaonad aalula. IhU 
Infanaatlon: i.a. tha ^acanlnatlon Df Claauo lanla of (-Hcythcofluoro- 
dtrte acid haa not vac bean accoapllahad by anyoa* {piavloua raporta aia 
doubtful), and our »(k in chls dinciion la praaantly haltad by tbt lack 
of fund*. Du* to oitlHaly high specific r.dlo.ctlvlty of o« laballad 
<-)icythrotluorotictlc acid (80-96,000 CPM/n ■oLc) « tta detect and 

poiaonait iDlnals (tot dacalls lec Flrat and Sscond Fingreu kporta) . 
Mntai : It ahould hm lecognlied that (O'cychTofluaToclcrlc actd aahlblw 

by tha follouing Te.cilon; Condanalog anayM 

> (->(E7throfluareelttlc acid + Co*. 

If F-clCiate wera iniaacad, ita toxicity la probably neill(abla, bocBoae 
(-) crythralluDCDclCclc Held, after aatarlni ealla Item the blood atrua, la 
efficlintly detoxified by the ubiquitous cycoplanlc aaayBe: ATP-cytnl* lyaaa, 
thet desvea f-cltclc acid to F-icetyl Coh + Oxalaeetate. The Blnuta aaoiaita 
of cytoplaaialc F-eeetate aftei hydrolyais of F-ecBCyl Co*, foned (roa ioiaalad 
F-citrate as preaent io tiafluaa of F-acatatt poiaoud aniiaala, ia probably not 
sufficient to produce lethal inioilemtlon eipeelally became (->ecythrofluoto- 
cltclc acid peneitoceB only to a Halted aiteot the callulal cucec unhrane fcoa 
the blood gtteim It (olloua that cenaiMption of tiaauaa of aalaala (by othar 
anlula) auccuabad to F-acelate la ualikely to ba hatatul, unleas [ha atoaach 
content (which aay CBBtaln unabsorbad F->cetate) It aalectively coDauaad. 
F-acatata in dacaylng tlaauca ia llkaLy to be defluotlnated in 5-10 houta to 
haiBlaaa slycolic acid + F-, thui a seiloui concern about 'apldaalc' F-acatala 
poiaonlnt through poiaonad circaisas appeara untaaaonablil Aa ahown in p[o|TUt 
Repoic 3, HPLC la i suitable technique to. Isolate tiaaue {-Jetythrofluotocltrlc 
acid (unlabaUad) uhen the labelled external atandetd l'c-labelled-C-)etythto- 

ftaction. Analyat* of r-acatata itaalt la aoat afllciantly dsna by tha CLC-M 
tachniquc davalopad tn tha labBtatory at DaBver. 



D,g,tze:Jb.GOOg[e 









G Out Biuuit work 


(»[ ■i.rpoEtHi by u.s 






( ■ novel mlciKhoedllal 


«.!]« tymum that !■ 


.pEcKlcally 


conCBnied wlchclt 




ttw inner ■.Itocl.o.idri 


ol -B-Urane ll 


Ilie lllialy cir(Ct 


aU. at Ihl. polaaa. 


lh« Mlecul.r MJe of 










[ pactlclDate 










^ U N : CI + esse + Wm + H* — — ^ GS-Cl + Hj" * ""* * "S" 

■nd identifiiul. Arrom • daicrlbi rniTBictc atcpai GS-Cl la cha cbloleitai of 

Ihc nubianc sgrfice to GSH <nd clitic icid GSSC - onldliad |lutaCblOB«; CSH 
- [idiiccd ilDCathlsMi'TPR - criphospliD pyridine nuclaoElda. 

(-) 117 thrafluBiaelt rate can enter Into caacclon 1 (aq. 2), uharaby F-clcryl-S 
-C is [anad ctaac reacc* vlth prouln 2 (P2) aE one -SH group and blocka 
lITCvaralblT cht eattca path. It un alto g-cltrvlate aconlta.e . which la 
Involved In the cniynaclc generation of TPMH, thua a double block la produced. 
Mote ! iwo atafet of 'lethal aTnthaaaa' are now lecogoited: First : the tetmr- 
atlon of F-dtrace froai F-acecate aa otltlnally dlacovered by Feterai Second: 
[he autcU* enayaatlc ayntheala of F-clctyl-tlutathlona, that la cha active 
F-dtrylatlna atent of at leaaC two dtaclnct ■eabcana proteina In ■Icochoodila. 



D,B,i..ab,Google 



ItfM onto cof^FltT of T-«e«ft«! ncuiol«Ultr 

I lahlblcloa at nilcchoadclalljr iTDCliMlttd ■ 

ln^aje ■e«tyli;holln« tmthMli in mptcilte bnin Emcira. data: If 

IchalliH ■yochiili can b« luppDrtad by (he gancTntlon of cytaplawle 

l-CoA, Chro |N-»ntita ln« no eo»tcttY - Thli »eu to ba tb* caaa In 

1 amslat ch»t aaitaar ra«l«t»nt Co >-»eetaca . It (allan that by 



•padta ata putleularly auseapclblt to r~acc[ata pelaonlag. 5>«11 todnti 
(•.|. rata) cntttdl itftai on ■Itoehendrlal cltrata foi CTtoplaaale autyl- 
cbollna aynchaala. Thla asplalna cbeli hlfh iBBalClvlt} to r-acatata polaoo- 



Blocba-lcal b«l» for 



of antlJot 



t tollOH 



[ tha t 



I toKlcltv . Ma tipd chat a vailaty of ecganlc dlnlfldaa can 
F-clcryl itoup, and em pcivaae Uw covalanc 
c to Fretalnj. It followa that If aftar Inteatloa 
lBal,(avahw«a) leeatvaa otgasle dlaalddaa dwc 
a CHS, than lethal toxicity abould ba pmantabla. 
Indead provea that eildlud glutathlona can coapletcly 
-citrylatlon. Adaptation of thaaa In «ttrn raaulu to 
Ira* axtanalTo-'fuHhar wnk, chat la noo lapoiBlbla.'Bt'UMt 
, having uda thlt pToJact catliely dependent on U.S. D.I. funda. 



D,g,tze:Jb.GOOg[e 



Congressional Research Service 
The Library of Congress 



WHhiiicUin. DC MiW 



Fabrusc; 22, 1980 



le [•ipoBie CO 7our request, I have ravleiied ttia 'Foucth (•umary} 
Report on Research coDcamad with tha long range project: developseat 
Of an antidota to fhioracetnte poiooning' (Dacaaber 9, 1979} bj Enert' 
Kun of the Univeraltf of CallfoToia at San Franciaco. Baaed on ay uodar- 
•tandieg of your needa (aa we dlaeuiaed on the tclcphona), I hava pea- 
pared a precia of the report, 

Plaaaa nota that thia precia qoIt aumaritaa tha report; no affott 
haa bean Mde to »«»a»> tha aeientific galiditT of the findlnna. nor to 
intarprat tha ftndinga . '- 

I hope thia precia is uaaful to you. If we can be of further aaala- 
tance, pleaae call h at 187-7227. 



In the background aactlon, the report notes that the precise toxic 
•etion of fluoracetate remains uncertatn, but indicationa of the present 
uork are such that "earlier infonsatlon is in serious doubt," These la-* 
dicatioos derive froa the following: 



D,g,tze:Jb.GOOg[e 



1, The report lay* that fluoracctati itself ta abntosie. Ionic ac- 
tion occura "only" if fluoracecat* la convectcd In ■ttochoodria (ccnapo- 
nenta uichin cella) to the toxic agent, uhieh la <-}erythrofluorocitTie 
acid. 

2, Intuting the toxic ageat (-)er]rthrafluoiocitric acid directly 
"probably" uould reault in "negligible" toxicity, aceotdlDg to tba ro- 

brane to a limited extent, and alao because Hbat does enter the cell will 
largely be detoxified before it reacbei the laitochondris. Ilhi* section 
of the report is particularly denae; thia it ouc best scan,] 

3, The report aaaerts that the aoounts of (')eEythrofluorocitric 
acid remaining in the tiaauea of poiadned anlnsls would "probably" be 

i. The report notes, however, that the auaunt of fluoraeetate ce- 
Diining in the stootch of ■ poisoaed anlnal could be harnful to an animal 
feedldg on the carcass and "selectively" consuming the stomach contenta. 

5. According to the report, fluoraeetate in "decaying tissues" 
would "likely" be converted to harnleaa substances in a few (S-10] houra. 
[It ia unclear whether this finding about hreikdown of fluoracstatea In 
"decaying tiaiuea" refers specifically to the unahsorbed reslduea pos- 
sibly present in the stomach,] 

6. The author. Emeat Eua. concludea that it would be "unreasonable" 
to be seriously concerned about en "'epidemic'" of fluoraeetate poisoning 
through tbs eating of poiaoned carcasses. 

7. The report says that the ultimata toxic actloD of fluoraeetate, 
uhen converted in the nltocbondria to the toxic setabolite (')erythro- 
fluorocltric acid. Is to interfere with the movement of certain chemicals 



D,g,tze:Jb.GOOg[e 



(citracai) acraaa tha incraeellular seabranei (within the ■itochondila) 
io nerve eclla. Thia InEerference, In tura, prohiblta the ayntheala of 
cheaical (acetylcholine), uhich i> eiaential to the transaittal of necve 
InpulBei. 

8. According to the report, the level of tonicity la affected by 
the pceaenca or abaence in the cella of anayBaa capable of ayntheaizing 
acetyleboline outaide the aitochondria. Kooning about the eniynea In 
the cella of apecific aniaala, "one ahould be able to predict Hbicb 
oniBal apaciea are particularly suaceptible to Iflnoracecate] polaoning," 

9. Tbia preliunary infotoatioa on tha eheaical rcactiona involved 
in fluorecetate/(-)eTythrofluorocitTic acid toxicity suggeata to re- 
aeatcher Kun that aome fora of organic diaiilfide night be developed aa 
an antidote. "ExEanalve" further reaeareh would be required. 



D,B,i..ab,Google 



80 

Mr. DE LA Garza. Thank you. 

Mr. Leath, may I ask you this. Is the report of Dr. Run ^rtiich you 
mentioned the fourth report of December 9, 19797 

Mr. Leath. Yes, Mr. Chairman. 

Mr. DB LA Garza. Very well. We had had a request to submit that 
into the record and your submission will suffice. We appreciate your 
doing that. 

Thank you very much. 

Mr. Lkath. Thankyou, Mr. Chairman. 

Mr. DB LA Gahza. The next witness is the Honorable Steve Symms, 
a Member of Congress from Idaho. 

Apparently, he is not here now. However, if he should not come, 
without objection, his statement will appear in the record at this point. 

The statement of Congressman Abranam Kazen, Jr., of Texas, will 
aUo be included in the record at this point. Mr. Kazen is not able to be 
with us today. Permission is hereby granted to include his statement. 

[The prepared statements of Mr. Symms and Mr. Kazen follow :] 



D,g,tze:Jb.GOOg[e 



Hx. Chali>aii, I appreciate this opportunity to appear before 
the Suboomnittee in »upport of legislation to require the Depart- 
ment of Interior and the Departoent of Agriculture to jointly 
develop an animal damage control program. 

In November 1979, Interior Secretary Andrua announced a re- 
vision in Federal animal damage control policy that will ultimately 
restrict predator control activities on both federal and private 
lands to the point of severely threatening the survival of the live- 
stock industry. Hot only is this in direct conflict with the ex- 
pressed intent of Congress which has continually voted to increase 
funds for predator control efforts, it is in defiance of existing 
law which charges the Department of Interior with controlling pre- 
dation to protect the nation's livestock resource. Since Secretary 
Andrus' announcement, I have received numerous letters from live- 
stock industrialists - the National Hool Growers Association, Inc., 
the Idaho Nool Growers Aasociation, the Sheep Producer/Environnen- 
talist Committee, all voicing theit adamant opposition to the Andcu* 
policy. I ask for unanimous consent to include several of these 
letters in the hearing record. 

Livestock loss as a result of predator damage has been a 
problem of long standing, and one of increasingly severe proportions 
in Idaho and other Western states. In 1977, for example, the 
■bMp indtwuy «i9wlaBe«a « in Iom 1a tlwlx ««aM laov* W • . 
raMilt of predator dsBag*. Thla repg — — f 13 ■llllBW ahaap at 
• total coat of 9TS0 million between 195S and 1977. Today, the 
sheep industry appears to be growing at a moderate rate but losses 
of aheep to predators have kept the figures frca rising aore sub- 
stantially. In 1979, total sheep numbers Increased 21 - the first 
increase In 20 years. Had there been a mote operative pr«datac 
control program in effect, this figure would have liicrea««fl iVPi^O"i~ 



D,g,tze:Jb.GOOg[e 



, nately an additional B« . These f Iguras represant a aubatantlal. 
amount of inccraa for the sheep induBtry, as well as having a aarkad 
effact to consomexB through increaaed prices of lanb nsat. 

B.R, «Ti5, the Anlnal Damage Control Act of 1980, will enact 
more effective and reBponaible methoda to control predators and 
Insure the devalopment of a sound and viable animal damage control 
program. Not only will thia bill allow for the use Of exiattng 
predator control techniques until nora suitable measuras can be 
found, but It alao emphasizes extensive research concerning lethal 
and non-lethal measures to determine their effectiveness in reducing 
predator damage. Host is«>ortantly, H.R. «T25 will finally speak to 
Congress' mandate in H.R. 9599 of the Tlat Congress on March 2, 1931 

'The Secretary of ILgriculture ia hereby authorised 
and directed to conduct auch inveatlgatlons, experimenta, 
and testa as he may deem necessary in order to determine, 
dononstrate, and promulgate the beat methods of eradication, 
suppression, or bringing under control on national foreats, 
and other areaa of the public domain, as well as on State, 
Territory, or privately owned lands of mountain lions, 
wolves, coyotes, bobcats, prarie dogs, gophers, ground 
squirrels, jack rabbits, and other animals injurious to 
agriculture, horticulture, forestry, animal husbandry, 
wild game animala, fur-bearing animals, and birds, and 
tor the protection of atock and other domestic animala 
through the auppresaion of rabies and tularoaia in preda- 
tory or other wild animals; and to conduct campaigns Cor 
the destruction or control of such animals: Provided, 
That in carrying out the provisions of this Act the Sec- 
retary of Agriculture may cooperote with the States, indi- 
viduals and public and private agencies, crganizatlons, 
and institutiona.' (Mar.2.1931,S.l,4G Stat. 1466.) 

It is in the beat interest of the nation that a strong, effective, 

balanced predator control program be developed. 

Without this legislation, the livestock industry will be in 
grave danger. And, without thia legislation, the economy of our 
nation will be in danger also. I urge the close attention of the 
Members of thia Body to the testimony brought before this subcon- 
mittee. I coomand the chairman's interest in positively addressing 
this issue which is so Important to the health of our sheep Induatry. 

I thank you for your tine, Mr. Chairstan. 

(The atcaetaatati Tcfsmd to follow:) 



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In your conUct with the Preeldent Eegefdiog thtg ^tteci pleaae neke It kacwn tb» 
Seccetecy Aodiua hii pieced hie speclel eiiieceDC Cynthle Hileon In cherge of the 
A.D.C. PlDBTW in his office. Hi. Hllloo hll 1 serlou* conflict of InCeceit In thi 
poltCiOD. Prior CO her eppolncnenc ehe tail e atell pereOD for Che Audubon SoclaCy 
end t> pceiencly Che Vlce-Chalnaen ol the Aolml Helfece InatlCuCe. Moreover, her 
teitlnony is on cecord ec preTioui heeclnsfl ■tetloft voGlferoue DppoBlcloD CD Adliia 

The Neclonel Vool Croweri AieocieclDO !■ currently celling for ove£el|hC heerlnsi 



D,B,i..ab,Google 



■BCa In tha Ilntl A.D.C. ■muHincMNnC from iitiat the Flih ind HildlKc Scrvlca 
D th* S«G[«t(iT and \*Mt th* Sccrataty announced wli hsavily Influeaud by 



In cloiLng, I WDUld Ilk* to point out that Iheapaan naclomtida ara concctnad wlch 
tha potantlal losa af thla Wcaceen Induatry. Such a dliiater wuld mean cba 
additional loai of narketa, buyeca, mllla, poola, packing faclllclca, health ore 
product* and equipmant auppllars to nana a fav. Tt would opan tha flood gacea of 
lii^iotta and could uall laduca the doDcstic Induatty to a hobby.. Ha cacnot allon 
thla te happen. Sheep have always been considered a mt tine snlmal. Produclns 
both food and fiber they are essential to our National Defense. 

Ue thank you for your time snd trouble In regarda Co this laiua and took forward 



^^.v/ a-^ac^-^.-^ 



Hr. Laltd Noh 

Hr. RoBcoe Meh 

Hr. Harren JUilstroa, Fish and Hlldllfe 



D,g,tze:Jb.GOOg[e 



MAR3U980 



: Unlversttyoddaho 



March 25, 19SD 



The Honorable Steve Symms 

United States Bouse of Representatives 

2144 Raybum Building 

Kashington, BC 20S1S 

Dear Representative Synuos ; 

SUBJECT: K.R. 672S ANIMAL DAMAGE CONTROL ACT OF 1980 

1 was pleased to receive your letter of March 14 concerning 
your CO- sponsorship of the above -aenti on ed bill. The following 
comitents may be helpful to you in your sponsorship of this bill. 

There is a substantial body of evidence to indicate that 
effective predator control is as important to the maintenance 
of wildlife populations as it is to the economic well-being of 
our livestock industry. Some years ago I attended a Congressional 
hearing on predator control in Sun Valley. At this meeting, 
representatives of fish and game departments from states in this 
area presented testimony indicating that predators do have a 
detrimental effect on gane birds, waterfowl, and big game animal 
populations. 

You may recall that in the early 1970's sportsmen in northern 
Idaho becane concerned about the very low elk calf survival rate 
in the Lochsa-Selway river drainage area. Studies conducted 
by the Idaho Fish and Game Department indicated that the calf 
survival rate was indeed very low, on the order of IS-ZOt, and 
that predators were killing a large portion of the elk calves in 
that area. Since predator control has been instituted in that 
area, the survival rate appears to have improved substantially. 
In this instance,, the principal culprit was the bear. Should 
you want confirmation of the above information, you night wish 
to contact the Idaho Fish and Game Department. Studies conducted 

portion of deer fawns if they are not controlled. 

It appears that much of the reluctance to allow effective 

in maintaining the balance of nature. However, I am sure that 
you are aware that the principal factor in unbalancing nature is 
nan and that most of the developaents in the history of human 



D,B,i..ab,Google 



populations to explode to an extent which >andates that, foi 
the human population to survive at the present population It 

.._ _.._. j^g actions which will maintain a selec 

-, human survival. The control of predi 
a level which will allow survival of 
domestic and wild anlnal species is only a part of this ver> 
complex struggle to provide food for humans and the maintenE 
of wild animal populations, which we see as important. 

Many people s 
effective in contr 

is abundant evidence that this Is not the case. If one studies 
the rodent eruptions which frequently occur and which almost 
invariably are followed by massive die-offs, one finds that a 
variety of diseases are the really effective factors in reducing 
rodent populations once they reach peak levels. 

There are also valid public health reasons for keeping 

Eredator populations within reasonable bounds. Coyotes are 
elieved to be one of the important vectors of rabies in the 
Intermountain West, Although we have not experienced sylvatic 
rabies outbreaks in recent years, if one goes back in tine to 
about Vorld War I, one would find that there was a major rabies 
epidemic in Idaho in which coyotes played a major role as vectors 
of the disease. Several years ago, the Boise Statesman reprinted 
an article from an Owyhee County newspaper entitled, "The Year 
of the Had Coyote," which described instances of mad (rabid) 
coyotes attacking farm aninals. People were afraid to go out on 
foot, afraid they might be attacked. Overall, the picture created 

conducted in Texas which indicates that coyotes ce 
of brucellosis, a serious disease of both humans a 

I hope these comments will be of some value t 
Very truly yours. 



Stewart Cruickshar 



D,B,i..ab,Google 



The Sheep Producer/Environmentalist Committee 



MflM41K3 



nt. Lynn fl. Greanualt 

fish and Uildlifs Ssrulca 
0«P»cti.Bnt nf Interior 
UashingtEH, 0. C. 20240 

The Sheep Producar/Enuironnsntal 



This UH variously 



stcessBd the nee 



enuIrDnniBntally 
rslying upon? I 
the lini 















D,g,tze:Jb.GOOg[e 



intBlligent, rHspansililB reaourcB managensnt. UnseiBnlirie thinking 
unlch uould ban ructhar camsaroU on compound 1080 nakai TutilB 
TBiearch into ather pianlsing auenuBS of coyote leanagaoant. Should 

Bdniniittatora dBny thB scientific validity or tneir uoiHI 
BecBuiB of the axoaEtlonal ability of the coyote to adapt, ua faal 






of thie fBct, or of 
and culturel struct 
TXle policy saans t 



3 ^-^ u.^ 

Co-Chelr 



D,g,tze:Jb.GOOg[e 



STAIEMDrr OF HON. UUHM UZOT. JS., A REPUSDRATIVI 

M cowBiss nmc me stat* of ibcas 

Mr, duliBm. I «ta1i to Join ocbn KabKs and a ban of conitltaait* In tba 
battla ■■■l4Ut caog* d^iac« hj prodators. 

AbrahK Lincoln ooe* uld that gorenant sUta to do foe paopla tboaa thtnga 
iddcb thtr cumac do (or UuBaalvaa. I eas ttalak of bo batter sapla tban itapplng 
op tba Eight 00 tba pradator a&alaa of l^ba, goata, calvaa and vlldlU*. Tbal 1« 
At I Introducad a bill, H.K. £733, daBlgnad to protacl tba lataraata of rancbv*, 
faiBara and otb«r pcopartr eanara by gmanBant action tbat mold anpport tbalr 
affoTta. It la ■; vlaa tbat H.B. 67IS, andac wtaatloD todar, coaU make a Bajor 
eootrlbutlon to thla Inporcant cauaa. 

It la vai7 tapoEUnt to fataara and ranebara «bo loot 32 Billion ibaap In tun 
dacadaa. In 1977, pradaCora* blUa accouatad for IT per cant of tha ahaap lahialry* 
(Toaa laeiaa. Tha-a arc bundtada □( fanar* trbo biva leat goata, and tba kill 
of yaong daar bad aarlooalT alaabed tba dear population is ■; Dlatrlct . vbaca maaj 
pTOpertr awnac* count on tnntlsg leaaca for Inportant eanb ravanua. Ha eatnot taav 
Aat loaaaa thsa bava baan In fowl and doaaatie anlaala. 

I bcllsra Tour C^lttaa baa aaan tha iilaatratlona in an artlda prlntad by 
Itngoan'* Journal In Aiguat. 197T. Tbtaa pbolographa of a eorota attacklig a aba^ 
biting II oo tha aar to bring It to tba gronnd, and than faataalng Ita taatb on tha 
throat of tba ahaap until Ita vlciti dlad of auftacatlon and blood loaa. I wold 
hopa tboaa pbotogiapba could gain tbc caraful attantlon Ot tboaa Hhs oppoaa 
pcadalor control bj aan, chooalig Inatcad to d^and on tba '%alanca of natura" 
thaoTT* I aoDU aafc than nbatbar (arnica and ranehara ara to baai thali loaaea 
wlthnit cnplatnt, wan aa aa aak thaa to balp Florida tba food and flbv aaaastlal' 
to all oar paopla. In good cDnaclanca, I urga that m protact aor paopla flral, 
and that va foeua tba Dapardiaat of Intarlor'a attantlon on antaal d^ga control. 



D,B,i..ab,Google 



Mr. DE LA Gakza. The next witness is also one of the distinguished 
new Members from Texas, who represents an area that has a vital 
interest in this problem. He is the Honorable Charlie Steobolm. 

STATEMENT OF HON. CHARLES W. STENHOLM, A REFBESENTATI7E 
IN CONGRESS FSOH TEE STATE OF TEXAS 

Mr. Stbnholm. Thank you, Mr. Chairman and Mr. Wampler, 
for extending to me the opportunity to testify before "y^our subcom- 
mittee this morning. I look forward to your bringing a bill to the full 
House Agriculture Committee in the not-too-distant future that we 
can act upon there. 

I am confident that much of the testimony here today will deal 
with the economic losses caused by predators, primarily coyotes, 
bobcats, and golden eagles in Texas, to those people now engaged in 
sheep and goat production- 

I would therefore like to talk about one of the biggest losses to 
our Stat«, a loss that can never be accurately calculated. That is 
the loss of a potential fiber industry to other areas of the State. 

The 17th Congressional District of Texas borders on the sheep and 
goat area of the State known as the Edwards Plateau. You can 
practically draw a straight line across the southernmost counties 
m my district and call anything below that line sheep and goat country 
and anything above the line no man's land as far as sheep and goat 
production is concerned. 

Let me draw you a mental picture of that area. The four southern- 
most counties in my district are Mitchell, Nolan, Taylor, and Callahan 



Counties, with just a small portion of C])oloman County. Wool produc- 
tion on the counties in 1978 totaled only 3 13, 000 pounds. At an average 
of 97 cents per pound, that meant revenues from wool production 



were $303,610. Mohair production during the same period totaled 
onty 61,500 pounds and was valued at some $313,650. 

Then, cross over that imagina^ line into the next four counties 
which are located in Congressman Loeffler's District, the 21st District. 
Wool production in those four counties — for the sake of simplicity 
I will concede my portion of Coleman in this case — Sterling, Concho, 
Runnels, and Coleman Counties — totaled 2,462,000 pounds which 
were worth almost eight times that of the production of the adjacent 
northern counties. Mohair production was 130,000 pounds and was 
worth $663,000, over twice uiat of my counties. 

Geographically there is no reason why sheep and goat production 
has been discontinued in other areas of the State including the 17th 
District. 

Still another point in favor of increased production in the west- 
central portion of the State is the running battle landowners face 
there with wasteful brush species. Goats, m particular, have been 
proven to be a cost-effective method of controlling certain types 
of brush, particularly scrub oak varieties, which are d^cult to control 
economically by other means. 

With increasmg pressures to limit types of chemical brush control 
methods now in use, I would think more and more landowners would 
be likely to consider the utihzation of goats in a brush control program. 



D,g,tze:Jb.GOOg[e 



41 

Let us look at the facts: One, mohair, at over $5 per pound, and wool, 
at 97 cents per pound, are economically attractive to livestock raisers 
in parts of the state outside the Edwards Plateau; two, much of the 
land is ideally suited to increased sheep and goat production; three, 
making full use of goats can be profitable as a brush control method as 
well as being economical animal units. 

Why, then, does the major portion of sheep and goat production 
stop at that imaginary line? 

It is just not worth the economic gains given the lai^e population of 
predators in our area. Predators cannot be saddled with the total 
responsibility for the lack of production, but when a cattle raiser has 
seen baby calves taken by predators he will certainly think twice before 
putting baby lambs or goats into the same area. 

The sheep and goat industry has been making a comeback in Texas, 
primarily due to strong wool and mohair prices during the past few 
years. The Texas wool clip increased 3 percent during 1979 according 
to the Texas crop and livestock reporting service. 

Mohair production was up 15 percent, the largest clip since 1973 
when the average price was $1.87 per pound 

The profit incentive is there. The necessary recourses are there. 
However, the predators are there as well. We do not have an effective 
efficient means to deal with the problem. 

As a cosponsor of H.R. 6726, I believe that this legislation is a 
step in the right direction toward achievii^ those necessary controls. 

I would emphaaizo that we are not talking about eradication of any 
predator species but about a program of predator control for the pro- 
tection of livestock and wildlife. 

I would like to thank you, Mr. Chairman, for givii^ me a few 
minutes to present my views on this sensitive issue. With a conscious 
recognition of the magnitude of the problem we face and with a 
concentrated effort by all represented here today, I am confident 
that we can set the stage for a responsible predator control program 
for Texas and other Western States. 

I urge my colleagues to support the passage of such a pri^ram in no 
uncertain terms so that the clear intent of Congress in this matter is 
unquestionable by future ^ency administrators. 

Thank you, Mr. Chairman and members of this subcommittee, for 
this opportumty. 

Mr. DE LA Gabza. Thank you very much, Mr. Stenholm. We appre- 
ciate your testimony. 

Without objection, the statements of any members who have not 
already been mentioned that may be submitted will be included in 
the record. 

I am going to ask the next witnesses if they will appear together 
since thffy represent the executive branch. I invite at this time the 
Honorable Rupert Cutler, Assistant Secretary for Natural Resources, 
Department of Agriculture; the Honorable Robert Herbst, Assistant 
Secretary for Fish, Wildlife and Parks, U.S. Department of the 
Interior; the Honorable Lynn. A. Greenwalt, Director of the U.S. 
Fish Mid Wildlife Service, U.S. Department of the Interior; and the 
Honorable Edwin L. Johnson, Deputy Assistant Administrator for 
Pesticide Programs, Elnvironmental Protection Agency, to come to 
the table. 



D,g,tze:Jb.GOOg[e 



42 

Are you prepared to appear this morning? 

Mr, Johnson. Mr. JelluieGk will be appearing. 

Mr. DE LA Garza. Thank you. I will advise the members of the 
subcommittee that I am advised that Mr. Greenwalt will appear only 
as technical advisor and that he has no testimony. 

Without seniority or order of importance but simply because we 
called you first, Mr. Cutler, we will hear from you. 

STATEMENT OF U. RUPERT CUTLER, ASSISTANT SECRETARY, ITAT- 
TJEAL RESOURCES AND ENVIROITUENT, U.S. DEFARTMEHT QT 
AORICULTURE 

Mr. Cutler. Thank you very much Mr. Chairman and members 
of the committee. 

I appreciate the opportunity to appear before you to express the 
views of the Department of Agriculture concerning H.R. 6725, the 
Animal Damage Control Amendments of 1980. 

The bill would require the Departments of the Interior and Agricul- 
ture to cooperate and in several mstances to jointly develop ana carry 
out an animal damage control program that utilizes both lethal and 
nonlethal control measures. 

The provisions of the bill recognize the need for immediate predator 
control using existing methods as well as the need for development of 
more selective methods of predator control to reduce livestock losses 
while protecting the environment. 

We support the concerns expressed in the bill but do not consider 
its enactment to be necessary because the Departments of Agriculture 
and the Interior as well as other cooperating agencies already have 
sufficient legal authorities to conduct animal damage control programs 
and associated research. 

Animal damage control is vitally important to the income of many 
livestock producers and other farm and forestry operators. USDA's 
economics, statistics, and cooperatives service estimates that amiual 
losses to hvestock producers attributable to coyotes is approximately 
$53 million. Becent data show that annual financial losses to the 
sheep industry alone approximate $24 million. Losses to consumers 
attrioutable to sheep or lamb predation approximate $4 million. 
Consumer losses due to calf predation are about $169 million. 

Livestock producers must be able to prevent or control attacks hy 
predators on their flocks and herds. Animal damage control aiso is 
essential to disease and insect control efforts. 

On the other hand, some pereons contend that there is little or no 
evidence that killing coyotes reduces Uvestock losses. They suggest 
that control programs kill nontarget species and are otherwise en- 
vironmentally unacceptable. Some believe the use of toxicants incurs 
too high a risk to the environment and to nontarget species. The use 
of toxicants is indeed controversial. 

Because of its economic and environmental advantages, the Depart- 
ment of Agriculture supports and promotes the concept of integrated 
pest management in all attempts to reduce economic losses caused 
by vertebrate animals. 

The goal of the Department is to reduce damage where animal 
damage reduction is determined to be necessaiy for economic reasons 
and if possible without environmental harm. When direct control is 



D,g,tze:Jb.GOOg[e 



43 

detennined to be necessary we focus control efforts on offending 
tmimaJs^ not on the species as a whole. 

The Department's animal damage control activities are based largely 
on the research of the Science and Education Administration and 
cooperating miiversities. Current predator control research is focused 
on fencing, guard dogs, attractants, and repellants. 

More extensive, integrated, and coordinated predator control re- 
search is needed. Relationships between control techniques, coyote 
populations, predation losses, and other wildlife should be further 
denned and assessed. Research should continue on new control 
methods as well as on more efficient and safe uses of present methods 
including the use of certain toxicants in heavy predation areas where 
other methods do not appear to provide sufficient control. 

The Department of Agriculture's objective is to develop a safe 
and effective predator control program for agriculture which ia en- 
vironmentally sound. 

We support the concept of using chemical toxicants, includii^ 1080, 
if not prohibited by other laws or regulations and if they can be used 
safely without a significant threat to nontarget species and humans. 
This includes the use of toxic collars where they can be used effectively. 
However, our goal is to develop and use other alternatives as soon as 
possible. 

We will encourage all research efforts directed toward the develop- 
ment of improved techniques using chemical toxicants to reduce the 
potential for harm to nontarget individuals and species. 

State cooperative extension services provide educational materials 
and programs on animal damage control for private landowners and 
mant^ers in every State. The extension programs vary from State to 
State based upon the m^nitude of predation of livestock, crops, and 
wildlife and tne significance of these industries and resources to the 
economy of the State. 

Development of educational programs is coordinated with careful 
identification of problems, attitudes, and needs of intended audiences. 
All approved methods for controlling a particular species causing dam- 
age are evaluated. Educational materials, techniques, metbotfe, and 
programs are then developed which incorporate the most practical, 
effective, species-selective, safe, and humane methods and procedures. 

Programs are implemented primarily through the educational sys- 
tems of county extension agents who provide group demonstrations 
and group training for producers with damage problems. 

On National Forest System lands animal damage control efforts 
are planned and conducted under the terms of a memorandum of 
understanding between the Forest Service and the Fish and Wildlife 
Service. There are also individual agreements with many States. 

Any animal damage control activities proposed on national forest 
lands must be carefully screened and evaluated before actions are 
approved. Where predators are involved, it requires a thorough docu- 
mentation of evidence of livestock or wildlife losses and coordination 
with land and resources management planning objectives for action to 
occur. 

In cooperation with the Fish and Wildlife Service, State agencies, 
and other interested parties target populations are identined, an 
environmental analysis is completed, and appropriate control tech- 
niques are determined. Actual control methods and their tiraii^ are 



D,g,tze:Jb.GOOg[e 



44 

specifically outlined in a detailed plan which is approved by the 
Forest Service. 

As a result of this ti^ht screening and the evaluation of critical needs, 
we have found that animal damage control is necessary on only a small 
percentile of the Forest Service land areas utilized by livestock 
operators. When a plan is approved, the control measures are con- 
ducted under the supervision of the Fish and Wildlife Service or, in 
some cases, under State direction. The results of control activities are 
closely monitored by the involved Federal and State agencies. 

The Department of Agriculture acknowledges the problem addressed 
by H.R. 6725 and recognizes the need for a solution to the predator 
problem that is acceptable to a variety of vaUd interests. We believe 
the eflfective solution is to continue to work toward a balanced pro- 
gram, involvii^ all predator problems and methods of control, utilizing 
existing cooperative arrangements between the Departments of Agri- 
culture and the Interior. 

Mr. Chairman, my associates and I will do our best to respond to 
questions from the committee. Thank you. 

Mr. UB LA Garza,. Thank you very much, Mr. Cutler. 

Next we have Mr. Robert Herbst, Assistant Secretary for Fish and 
Wildlife and Parks, Department of the Interior. 

STATEMEKT OF EOBERT L. HERBST, ASSISTAin; SECSETABT, PISH 
AUD WILBIFE AND FARES, U.S. SEFARTUENT OF THE IHTEEIOB, 
ACCOMPANIEl) BY LTNN A. GBEEKWALT, DIBECTOB, U.S. FISH 
AND WILDtlFE SEBVICE, U.S. DEPAETMEMT OF THE IHTEEIOE 

Mr. Hehbht. Thank you, Mr. Chairman and members of the com- 
mittee. I welcome the opportunity to testify on behalf of Secretary 
Andnis on H.R. 6725 and H.R. 6733. 

This legislation would require the Secretary of the Interior in co- 
operation with the Secretary of Agriculture to implement certain 
requirements relating to animal damage control. 

Since this legislation does not consider the adverse impact on wild- 
life resources or the environment, addresses only a portion of the total 
ADC program, and is almost entirely encompassed in the Animal 
Dam^e Control Act of 1931, we must oppose enactment of the bills. 
Our legislative report, which is being prepared, will analyze the bills 
in more detail and give our rationale for opposition. 

In my statement I would like to develop what we think are the most 
significant issues: The current ADC program's direction, the continua- 
tion of the use of compound 1080, and the failure of the bills to address 
the total animal damage control program. 

Mr. Chairman, this controversy emerges from two basic and un- 
([uestioned facts. The first is that predators includii^ coyotes play an 
important role in the ecosystems they occupy. The basic predator- 
prey relationshijB between coyotes and rabbits, mice, and other prey 
species are complex. In unmanaged situations their populations fol- 
low cycles, with reductions in prey species populations beii^ followed 
be declines in predators. 

A balance of predators andprey is often the sign of a healthy eco- 
system and is something the Department of the Interior and the Fish 
and Wildlife Service is committed to protect. 



D,g,tze:Jb.GOOg[e 



46 

The second fact is that predators sometimes kill domestic animals, 
in some parts of the country to such an extent that they can be a 
source of major hardship. At the request of the livesto<nt industry 
the Secretary directed tne Fish and Wildlife Service to conduct a 
thorough review of our predator control programs. 

Following a 21-month review — complete with public input — of the 
Federal role in controlling damage by predators, the Secretary recently 
issued a revised policy on the program. We believe it is a reasonable 
approach to resolve a controversy which until now has seemed to be 
characterized only by the extremes. 

The Secretary's decisions were designed to restructure the ADC 
program to better assist the sheep industrj' in reducing losses from 
predators in an environmentally acceptable manner. He set long-term 
goals, such as minimizing the use of lethal controls, but he recopiized 
that these goals cannot oe achieved until research develops effective 
alternative methods. 

In the meantime, we will continue to employ our short-term strat- 
egy, that is, the continued use of present control techniques such as 
aerial hunting, trapping, and the M-44. These will be used in the most 
selective manner possible. 

The poUcy also calls for increased field research on both lethal and 
nonlethal control techniques and the effectiveness of various husbandry 
practices in reducing livestock losses. This would include further re- 
search into scare devices, aversive agents, fencing, and other methods. 
As new methods are perfected we can perhaps limit or phase out some 
lethal techniques. 

Nonlethal methods will have to be proven to be eflective and accept- 
able before we adopt them for predator man^ement. The expanded 
effort to test these methods in the field will be an important part of our 
research program. 

The new ADC policy is an attempt not only to update our program 
but to recognize the realities of the 1980's. One of these realities is that 
compound 1080 is so controversial and arouses such high emotions that 
it may never be accepted by a majority of society in any form. 

It la true that the Secretary did not accept Director Greenwalt's 
recommendation to settle the question of compound 1080 once and for 
all through expanded research. Bear in mind that this recommendation 
was made strictly from a scientific standpoint. He estimated that it 
would take no less than 3 to 5 years and would require an additional 
$1 million and several permanent full-time personnel to answer the 
cruci^ questions about its safety and efficacy. 

After considering all sides of the issue the Secretary decided that 
continuii^ to study compound 1080 would be a waste of taxpayer's 
money, and even if its use were to be tentatively approved that decision 
would almost certainly be subject to long and costly litigation. Instead, 
it was decided to devote our research funds to seeking another toxicant 
which is effective and environmentally acceptable as well as studing 
other methods of control. 

The Secretary also discontinued the practice of denning, that is, of 
locating coyote dens and killing the pups. As you may know, this 
practice accounts for a small fraction of coyotes killed by the Federal 
program, but it is a practice which is repulsive to a majority of 
Americans. 



db.Google 



46 

We believe the elimination of denning as a management practice is 
an excellent decision. The reduction in the program resulting from this 
directive will have a minimal impact on livestock losses and will make 
the Federal program more acceptable to the public. 

We will, however, take pups from their dens when there is a rea- 
sonable assurance that they will starve to death if left there. The pups 
will only be taken by hand excavation of the den and pups then diis- 
patched by shooting. 

The proposed legislation does not supersede or contradict the Animal 
Damage Control Act of 1931 but merely refers to a portion of the act 
and provides a more precise definition of the methodology to be 
employed. This proposed l^islation fails to recognize the nonpredatory 
animal damage control aspect of the ADC program. 

The total ADC program includes the protection of agricultural 
crops from rodent damage, protection of food and agricultural crops 
from bird damage, prevention and spread of diseases from wildlife to 
domesticated anunals and humans, and the protection of human health 
and safety, especially with respect to the problem of bird damage to 
airplanes. 

Upon careful examination of the current animal damage control 
pri^ram, including the objectives stated in the recent decision by the 
Secretary, one soon realizes that most of the intent of the proposed 
legislation has been incorporated into the program includii^ the 
formation of an interagency working group and Research Advisory 
Committee. 

The Research Advisory Committee will insure that new ideas are 
given attention and will oversee the application of research efforts 
mcluding the drafting of a 5-year research program. The committee 
will include representatives of the livestock industry, the environ- 
mental community, academia, the Council on Environmental Quality, 
the Environmental Protection Agency, the Bureau of Land Manage- 
ment, the Forest Service, and State wildlife agencies. 

The formation of an interagency working group, comprised of 
representatives from the Bureau of Land Management, Forest Service, 
and the U.S. Fish and Wildlife Service, will assure that animal damage 
control activities on public lands are in harmony with other objectives 
which guide the management of those lands. 

Mr. Chairman and members of the committee, let there be no 
misunderstanding. We will meet our animal damage control obligations 
as mandated by the Animal Damage Control Act of 19.31, the National 
Environmental Policy Act, and other pertinent Federal statutes as 
well as the President's 1977 environmental message. 

Mr, Chairman, I will submit for the record copies that concisely 
state the Secretary's decision and outline the implementation plan 
and the time schedule for the implementation. 

With me are Mr. Greenwalt and his staff. This concludes our 
statement. We wiU be glad to respond to any questions the committee 
has. 

Mr. DE LA Garza. Thank you very much, Mr. Herbst. Without 
objection the material you intend to submit will become a part of the 
hearii^ record when you have submitted it. 

(At the time of pnnting the material had not been submitted.] 

Mr. DE LA Garza. We mil hear now from Mr. Jellinek of the Eh»- 
vironmental Protection Agency. 



D,g,tze:Jb.GOOg[e 



47 

STATEHENT OF STEVEH D. JEUIHEE, ASSISTANT ASHIKISTBA- 
TOR, FiSTICIDES AND TOXIC SUBSTANCES, ENTIRONUENTAL 
PROTECTION AGENCY; ACCOHPANXES B7 EDWIN L. JOHNSON, 
SEPUTT ASSISTANT ABKINISTBATOR, PESTICIDE PBOaEAUS 

Mr. Jellinek. Good morning, Mr. Chairman and members of the 
subcommittee. I appreciate this opportunity to discuss with you 
EPA's views on H.R. 6725, a bill introduced by Chairman de la 
Garza and Mr. Loeffler. 

H.R. 6725 seeks to signiiicantly reduce annual losses of livestock to 
predator attacks by directing the Secretaries of Agriculture and the 
Interior to jointly conduct a balanced animal damage control program. 

Among other measures, this program would include the use of 
compound 1080 and other toxicants until more suitable selective 
toxicants are developed. The bill also calls for research activities on 
chemical toxicants including compound 1080. 

I assure the subcommittee that EPA is in full agreement with the 
sponsors of the bill on the importance of the U.S. hvestock industry. 
At the same time, we recogmze that the industry needs a variety of 
aj)proved control tools, both chemical and nonchemical, in order to 
minimize losses of their livestock to predators. 

However, EPA's pesticide regulatory mandate, the Federal Insecti- 
cide, Fungicide, and Rodenticide Act, makes us responsible for 
insurii^ that predator control toxicants, like other pesticides, can be 
used without posing the risk of unreasonable adverse effects to humans 
or the environment. 

Our role is to evaluate the risks and benefits afforded by various 
predacides and to allow public use of only those that offer social or 
economic benefits that outweigh their accompanying risks, 

Mr. Chairman, EPA opposes enactment of H.R. 6725 for the 
following reasons. First, it would mandate the use of compound 1080 
and other toxicants without the requirement of a risk-benefit analysis 
to determine if such predacides could be used without unreasonable 
adverse effects; second, it would set a precedent for similar actions on 
other pesticides; and, third, its relationship to the normal misuse 
prohibitions and other provisions of FIFRA is not clear. 

For example, if the bdl is intended to set aside FIFRA's registration 
provisions for predator control toxicants, does it similarly preempt 
FiFRA'a prohibition on pesticide misuse for such chemicals? And 
would sanctions be available E^ainst control program operators who 
used compound 1080 in a manner inconsistent with Interior-Agricul- 
ture approved practices? 

Compound 1080's predator control uses and those of strychnine 
and sodium cyanide were canceled and suspended by EPA m 1972 
after the President's Executive Order 11643 banned all use of predator 
control toxicants on Federal lands. 

The Agency's findings at that time was that the three compounds 
posed unacceptable hazards to humans and other nontai^et species, 
especially considering their typical predator control use patterns. 
Further, use of the three toxicants for predator control was found to 
confer only ill-defined and speculative beneOts. 



D,g,tze:Jb.GOOg[e 



48 

Subsequent to the 1972 order several EPA-approved experimental 
use permits provided for further testing of sodium cyanide. Ul- 
timately EPA's iindings on that chemical were modified by the develop- 
ment of new factual information regarding the relative safety and 
selectively of sodium cyanide as it is delivered through the M-44 
device. 

In 1975 sodium cyanide was again registered for coyote control 
use but in the safer M-44 device. Basically, EPA found that the 
M-44 is selective for canids and poses only minimal hazards to non- 
tai^et animals. An eflfective antidote exists for sodium cyanide 
poisoning and the experimental use of the M— 44 appeared to result 
m a trend toward decreased losses of livestock to predators. 

As this renewed registration action cleiu-ly illustrates, FIFRA does 
embody the flexibility needed to adjust historical regulatory decisions 
to new biological technological, or economic realities. 

During the late 1970's experimentation with 1080 also was conducted 
by USDI under a series of experimental use permits approved by 
EJPA. From 1977 until late 1979 Interior conducted field tests to 
evaluate the safety and effectiveness of 1080 used in the toxic collar 
device to control predating coyotes. 

Interior's goal m conducting this research was to gather the type 
of substantial new evidence on 1080 that is needed under EPA's 
subpart D rules of practice to support renewed registration of any 
canceled or suspended pesticide use. 

Late last year, as you know. Interior announced its decision not 
to pursue further research on 1080 for predator control but instead 
to focus its research efforts on nonlethal control methods and other 
toxicants that do not pose secondary poisoning hazards and are selec- 
tive and humane. 

To date, EPA has not seen significant new evidence that would 
support a modification of our 1972 risk-benefit decision against the 
predator control use of compound 1080. We remain concerned that 
reintroduction of 1080 as a predator control toxicant could cause 
serious secondary poisoning and other adverse environmental and 
human health effects, 

H.R, 6725 also directs Interior and Agriculture to conduct animal 
damage control research using toxicants including compound 1080, 
As I mentioned earlier, research with 1080 has been conducted by 
Interior during the past several years under an experimental use 
permit approved in accordance with section 5 of FIFRA, EPA would 
cooperate in a continuation of such research. 

However, I must emphasize that while the data gathered through 
such a research program might ultimately be used to support renewed 
registration of tne predator control use of 1080, registration of 1080 
would not automatically result from the program. 

In accordance with subpart D of EPA's rules of practice, if EPA 
were to determine that substantial now data had been generated 
which might materially affect its prior cancellation-suspension order, 
the Agency would convene a formal pubbc hearing to examine sucn 
data. Any interested party would be given an opportunity to take 

§art in the hearing. At the conclusion of the hearings, EPA would 
etermine whether the new evidence on 1080 materisdly affected the 
prior cancellation-suspension order and required its modification. 



D,g,tze:Jb.GOOg[e 



In inviting EPA's testimony today, Chairman Foley of the full 
■ Committee on Agriculture asked that we also estimate the cost to 
EPA that would be involved in implementing H.K. 6725. We do not 
believe that enactment of the provisions of the bill would have any 
measurable impact on the cost of conducting our pesticide regulatory 
program during this or the next 5 fiscal years. 

If USDI and USDA were to conduct a cooperative animal damage 
control program as described in H.R. 6725, we anticipate that the 
registration and other ongoing activities of our program would simply 
continue to function as usual. 

In summary, FIFRA sets forth provisions for the equitable and 
scientifically supportable introduction of pesticides into the market 
m.d for removal of those pesticide uses that are found after registra- 
tion to pose unreasonable adverse effects. FIFRA further provides for 
experimentation with an emei^ency use of unregistered pesticides, 
consistent with the overall goals and purposes of the statute. 

EPA has developed procedures for reconsidering previous cancella- 
tion or suspension decisions so that pesticides which have been 
removed from use may be reintroduced at some later time if substantial 
new evidence changes the Agency's previous risk-benefit findings. 

Thus, EPA cannot support any legislation which mandates an 
unregistered and unregulated pesticide's use. An efficient working 
regulatory system is in place that insures that all pesticides to be 
used in this country are equally and fairly evaluated gainst the same 
unreasonable adverse effects standard. 

That completes my prepared statement, Mr, Chairman. I would be 
pleased to answer any questions you may have, 

Mr, DB LA Garza. Thank you very much. We thank all of you for 
your testimony this morning. 

Mr. Wampler? 

Mr. Wampler. I wonder if you would tell us something about 
your background, Mr. Herbst, 

Mr. Hehbst. Certainly, I have a degree in forestry and one in 
wildlife. I was an instructor at the University of Minnesota in forestry. 

I spent 7 years as a practicing forester in the Plumas National Forest, 
in the Superior National Forest, and in centra! Minnesota, 

I was public relations director for the Division of Forestry, execu- 
tive director of Keep Minnesota Green, Inc., for 2 years, which posi- 
tion dealt with environmental education, fire protection, and mainte- 
nance of the tree farm program. I was deputy commissioner of the 
Minnesota Conservation Department, acting commissioner of that 
department for 3 years, ana then became the national executive 
director of the Izaac Walton League. 

I returned to Minnesota as commissioner of its newly established 
department of natural resources and served as its commissioner for 

II years, 

I was then selected by the President and confirmed by the Senate 
as Assistant Secretary of Fish, Wildlife, and Parks for the Department 
of the Interior. I have had approximately 27 years of professional 
background. 

Mr. Wampler. Then it would be fair to say that your credentials 
are basically those of an environmentalist. Is that correct? 

Mr, Hbkbbt. My credentials are those of a scientist, a natural 
resource manager, and a natural resource administrator. 



D,g,tze:Jb.GOOg[e 



50 

Mr. Wamplek, That is why I find your statement almost un- 
behevable. On page 3 of your statement you say: "It is true that the 
Secretary did not accept Director Greenwalt's recommendation to 
setUe the question of compound 1080 once and for all through ex- 
panded research." 

As one who, I assume, has some appreciation of scientific reasoning, 
why in the world did you not let msinterested people, people who 
could tnily question accepted methodologies, research the issue rather 
than malung a political decision? It looks to me as though it was 
made solely on the basis of what you perceived to he sound public 
policy in the political realm rather than m the scientific realm. 

Mr. Herbst. The Secretary made the decision himself, personally. 
The Director recommended that we complete the research to answer 
the questions once and for all and estimated that it would take from 3 
to 5 years at the costs and manpower that I indicated to you. 

The Secretary felt that it was a waste of money to continue the re- 
search, that even after that period of time if the answer were favorable 
the Utigation would be such that the process would be drawn out for 
such a period of time that use of 1080 would never come about. So, 
that was the decision the Secretary made. 

Mr. Wamplbr. What recommendation did you make? 

Mr. Hehbst. I made a supportive recommendation of the Director. 

Mr. Wampleh. I commena you for that. 

Let me just say that if Congress were to legislate on the fear that 
whatever we did was going to be litigated, we would never get anything 
done here. Most of what we do here at one time or another is subject to 
litigation. I think that is contorted thinking. 

It is sound public policy to submit these very complex questions to 
sound scientific determination. Unless you do that, I think you have 
missed a great deal of what your responsibility is. It is to try to let the 
scientific community tell us what the facts are and then let the regula- 
tors and politicians make decisions on the basis of sound scientific 
judgment, not on the basis of political judgment. 

Mr. Hehbst. I would point out to you, Mr. Chairman and Mr. 
Wampler, that the Secretary's decisionmaking process is one in which 
he addresses and takes into consideration scientific advice, legal ad- 
vice, economic advice, and the other types of advice which he must 
examine in order to make a decision. He felt that research had been 
continuing since 1972, that no favorable answer had come about, that 
another 3 to 5 years of research optimistically was about to take place 
at the kind of costs involved, and that we ought to move and strei^th- 
en our research in the areas of finding answers that would be more 
acceptable and possible. 

Mr. DE LA Gahza. Will the gentleman yield? 

Mr. Wamplek. Yes, I yield. 

Mr. DB LA Garza. I want to be sure I understand Mr. Herbst's 
statement. You say that you supported the recommendation of the 
Director, Mr, Greenwalt. Is that correct? 

Mr. Hebbst. The process in the Department tor making decisions 
is for an agency Director to make his recommendations to his or her 
respective Assistant Secretary, which in this case was a recommenda- 
tion from the Director to me. 



D,g,tze:Jb.GOOg[e 



Itcaultt or aDimri poMd bf tbt tw raMateh tactBBandattooa (3, )) 
■>r h* raalltad In m lai» than )«S r*a'* >n< woald ra^ntn an tnlttal 
- addttloul $1 >llll(m avar tha FT 1979 laval andrU panaoaM full- 
tlst paraesnat* 

On* of tba k«r laiuai nlatlog ta tha control af dtpndatln) iBloals 
coDCcrM th« uia of toitcant*. Ona iIki boldi that all toiieanta 
ahould ba done auar vlth and that other alctrnatlvta — prtlarahlr 
aoft-Uthal— ba d«v«lopad. The imeatoek op«r«tor« feel ■trongl)' 
that aoaa kind of toalcant auic be dBveloped and uaed !□ ■ rational 
way. Ftovldad that raaeatch raiulti conclude that CoapoBsd lOSO 
offer* the brlghtait ptoalaa ii tht 'coiieant of cholea* and can t« 
leeltterad through EPA, an addltlooal requlreaeat prtar to «•■ la a 
Federal prottaa, vould b« ao aneBdMnt to Executive Order 11M3< 

Kijor quettlona to ba aDaverad thrttugh reaeareh tncladai la It a* 
eff IcBcloui/hanful ai preaently pirecived; can It ba Bade aceaptabla 
under tha law; does It oi aoae other toctcani aeet the aaed* of aa 
t-fccttv* ar-J'il damige oBnagcBegt progruT 

Other coilcant raiearch ahould be eonductad aa a practical qnaatloa 
and to lay to rest the eootlnulng quastloa about the avallabllttj 
of a aalactlTa, target apeclfte toxicant or toxlcaaca that can b« 
uaed In aoae racloDally applied way in thote circuutancea uhOB 
denonatratad tkeed for costrol paralta tha uaa of no other aatbod. 

I TccootMad that applied field reaeareh ba Initiated an aoa-lecbal 
coQtrol teuti.i;4uai and tb« affacttvaaaai of buabandiy praetteea In 
raduclDg llvaitock loaaae uadar vartoui flold condltlonf. 

ptla leacatcb absuld be conducted, a* ulth aeae tosleaeta, to prerUa 
anauera to the coatlnulng ^ueatlone iiEerdlng th* effectUeaeaa of tha 
cachnlquea. In oidat to carry out a reipoaalblc progTaa, «a BUit 
knou the full aiiar of the aoit effective techolquea available, l*a> 
acaia davlcea, avacatva agenta, fencing, tncraaead nee «f herdera, ate 



The queatlon of preventive control ta a major one. FraraDCtvo cm' 
trol lapllea the cootrol of carocea In areai frciiueDted by atock, 
or about to be used by (tack and which are aotad for their hlatory 
of depredatlona. Id thoit, utlDg controla before the coyotea and 
tbalr pror com together and a problan teeult*. . 

Ftevenctva crntrol la effective In certain laataocaa, and le Glaarly 
aought •ftei by aany aptratort who perceive thle aa a aalottoB far 
the*. HovevcT. prler to Inltiat *s prevcnttee control everir effort. 
I.e. eiteneloa, Boeletha] noncapiure, huabandry practices, etc., to 
reduce the e<...;ilct problas ahould be *aplo]Fod uhecc practical. 



D,g,tze:Jb.GOOg[e 



On* obTlaui •oluclM) t* tb* ptoblaa of hl(h pradscloa mi public 
Uada It ta dtlcmilate staling on thoia ■[«■* luictptlbl* to •>- 
-trnc hlfh t«tu or to rcdcslgaacc iboie Mtttt to Mbtr iM«i. Mmk 
tbl* 1* ■ practical appioacti. Ic It clearly a daairabla courM of 
action. In thoic clrcuBscancea vhere thia la not practical, ac- 
tivltta* Mill be eoDduetad that ulll rccognlie and uphold the valuaa 
laponant to all AaiilcaBi to the •ailaua •itent peailbla, and be 
coapatlbla wtth Bultlplc-ua* and auataload jleld prlnclplaa. 

I racaaMnd that, la accordanc* tflth tha Prialdeat'a 1977 CnTlroB- 
MBtit Hettage, the (oUovlng dcflnliloD of 'offending aatsAl" be 
adapted I The Indlyldjal or local populatlen camlBK dacage er 



1 luppott the preiid«BCtBl dliecclva 
of Che rol* that predator* plar la vs 
coptrol li neceisary ft ahmld focua 
cauting the problea — not the (pccl*s as a vhol*. Uavever, I «a 
Teluctaul to conclude that the ladlvldual culprit suct'be Idenclflad 
before Utbal coaccol acClvltlea caa be anplayed. Knowledge gaioad 
through reieaich will be uaad to eatabUlh rcssooable atandarda aa 
to furtbar tdantlflcatloa of *ffBDdliig antaala. 

Ha are aot appotad to tba Idea that loaaea to ptadatora Miat b« 
aiCabUihed prtor to coDductlag predator daaage Mnageaaat. Ih* 
aactptioD to thla prcalae would apply in the clreumataneaa deacttbad 
abe«« Id tba uaa of pravantl** conttol. 

6. I racgaHBd that daoDlnc, •• • aanagtMat practtca, ba allalMMd* 

TtM •ItalMClen of daantBi aa • MoaiMant practice could ba 
aeesapllihcd with olnlBal affect on Uveatock loaaeti Ic abould 
b« polncad Mt, bow«v<t, that buDaDeaest way requlTc the takloc of 
denoad pupa In thoae Inttapcaa wbaa a lactatins tawle baa baao 
found to ba aa effandlns aalMl aad la takea aa auEh. 

7. I raeoaaand that the tola »t •ileBalao ba aKpaudad. 

A graatar aaphaala oa titaoaloa will ba accoaptlahed through r«- 
naulng The Kenoiandue of Usdecataadlag vith USDA, Incieatad aelf- 
hclp etfoiti (desoBatratlana), Iscraaiad cooparatlo* with lead grant 
uDltferaltlea and county axtenaloa agaata aad aa a Mana to dltieal- 
'oata Inforatelon on oaw or different tacbalquaa available for aalaal 



Tba eonduec af the ptntraa vlll daiarvn Eontlnulng aerutlny and 
■uch avaratgbt will ba deaandad aa a political taality. Ihia ad 
hoc bodj, Mde up af the affected Intetaeta and othera wha have a 



D,g,tze:Jb.GOOg[e 



■taka In pr«d«tor auuiaaadt, wauld coodoet •ucta * zavlw at tht 
mat flf tba flHt. t|Urd tad IKth yaara of tb* SM-rracrM. TkU 

- body Muld b« cbaiicd oitb tte ttipoDilbllltr for aiitiitag Cha 
prolriB aod 1C« adhcraDca ta tha nau pollcir, and the daHalopaant 
ol iicoaBtadaClDBi for cMBS* In that poller, b>*«d upon th« ra- 
■ulti «f tbc tavlaw. Thui • me at Bid-couci* coiractlaoi caald 
ba dtvaloptd at leaat twlGa durlat th» flrat ftva yaait •( tb* 
Mv affsrt. 



A •■]» affart Ee mcructara tha fundlnf baa* of tiM oparatloaal 
progriB ahould ba andartakan. AC piaaast tb* opatatloul alfoTt 
la fusdad bjr • nixtura of Ftdeial appTaprlacloD, Stata appropita- 
tton, a *haad tu' od llvaicock lod other •ourca*. la varlad «lx«i« 
rha FVS paraoanal in charge ol [he pTOtran hav* aluar* bcea iQtl- 
aattlr iovolvad la cbc dtvelopMot at tba aOB-FadaTal bud(ala for 
th* prograa, oftan at cht iTouni) la>el (l.a. , laaktog fuodi fres 
opafotora to luppliaaDc other fundi to carry out a full pTDgraB)> 
Tbli haa alwaya aada It virtually Inpoiilblc for tha Sctvle* flaU 
paraonaal to aupport aor nrlatlon of the ptograa aatda fioa ahat 
tba local oparatori tanc — tht (laid parton la ta an oatanabla 
poalttoB of ImvIds te provlda a coatrol prosri* la kaaplns with tho 
fvndlai available, iihatliar tc 1* an apptoptUt* prograa ar not. 
Dta poailbllltlaa of p«rp«tuatln| archaic or unaacaaaary work aia 

Tba contribution* of Stacaa and lacal (rowpt —Including growtra— 
ahould coatlBua, but ba dtvotcd to aitassloo, taaaarch and taprovai 
buabandry Bctboda, Ibui finally allmlnatlng the veitad lavait««Dt 
atructiua that hat coctrlbutad to an Inability to «iWe fuadanental 
cbaagat In tbt antnal idasagc Binai*Mnl ptogrU vet tlaa. Tha 
detail* of aueh a plan itmain to ba woikad out, but the objcctua 
ahould be to have all operational aaloal daELage unagcaent funded by 
tba Fadatal tovaraaant ao long a* It li raiponalblc for the piagraa. 

lb* reco^ndatloni »ide abova Mould ratult In loae iBportaat cbangaa 
la hOH FUS anlul daaige aanageiHEt li conducted and cupervlied. It 
la at laatad that thcie changci vtll require an additional %5 Billion 
Initially for Operation* (lncrei>ed eiitnslon actlvltlei, addltlODat 
ninpouer required (or mphiili eo corrective control and aelectlve control 
Mthodt' and luppllat and aqulpHnl) and $1 •llllon for Reiearch for a 
tatal of tl7.2 alUloD la n 1)«0. Jtn additional tnct***i a( •! parwanant 
full ClM poatt ti vould be required. 

I b«ll*v* that th*a< racODBendatlon* vlll aatltfy BMt peepla an 
bath (Idea af th* 'iiue and etlll allow _(o( aa *ff*ctl*a anlaal daMg* 
■anagaaant prograa. Given the funding personnel, aad acceptance af 
Cbaa* TacBOMBdatlona, It 1* alan believed that ll**atoefc loaae* and 
th* sdvatta affacta ea wtldllf* Muld d*cr*ata. It abould, bowavnr. 



D,g,tze:Jb.GOOg[e 



It !• clur that bo ilapla aolittloD to tb* avsrall ^aMtlon of •ntatl 
^•■■CC aaiug*sant policy cso b* ^vvlopcd. It will rtqulr* a ■!> of 
approach*!, tailored to the placa, topograph)', and tlat *f yaar; tmbodjlDg 
tht policy that a grtatar aaphaita b« placed aa corractlva control and 
••Icctlva control nathad*. Than !• alio the natd to ccaDuntcata ttit 
unfatitandlng to all partlaa aa to the rot* and valuo of pradatora wtMn 
thajr ara proparlr Biaagad le a* to play thalr aaaentlat roU tn the 



4 







.oJi- 



D,B,i..ab,Google 



Mr, Wamplek. Finally, Mr, Cbairman, let me just say that I have 
been concerned, as a member of this committee for a goodly number of 
years — and I do not single out the Fish and Wildlife Service or the 
Department of the Intenor because it applies ejiually to the Depart- 
ment of Agriculture, the Environmental Protection Agency, and oth^ 
regulatory agencies of Government — that in trying to interpret and 
carry out the mandates of Congress, I feel, in all too many instances 
you are bending science. 

You are not turning to the scientific community that could provide 
many of the sound answers to the problems that we are probii^ today 
in trying to find workable solutions, I think every member of this com- 
mittee is concerned with the legitimate effects of the use of chemicals 
and pesticides have on the environment. 

On the other hand, we have some responsibility to the American 
people to assure them an ade(iuate supply of food and fiber at prices 
that the woiking people in this country can afford to pay. 

Mr. Poage, the former chairman of this committee, once said in 
commenting upon a subject very similar to what we are discussing 
this morning, that in the minds of some the whale or the coyote is more 
attractive than a lamb chop on the table that can be eaten at a price 
that people can afford to pay. 

Here are the two extreme viewpoints on this matter. I think there is 
a better way to proceed. I cannot find words strong enough to condemn 
the Secretary of the Interior for failing to turn to the scientific com- 
munity to help find the answer. 

I do commend him for having in mind sound management and 
economy, but, as I understand your statement, he is going to go into 
another area of research where there may or may not be some hope of 
finding an answer. 

I believe, Mr. Chairman, that you are right. We ought to have the 
Secretary up here. If this is a political decision — and he has every 
right in the world to make a pohtical decision — let us let the American 
people know that it was made on the basis of his conception of what 
was sound public policy, whether it is political, environmental, eco- 
nomic, or whatever it might be. 

He is absolutely turning his back on people who are in the position 
to give us a scientific answer and to me it is incomprehensible. 

Mr, Hebbst, Mr, Chairman, let me comment. The Secretary did 
not turn his back on that. He did take the scientific facts to date into 
consideration but he also took economics and the side effects, or 
potential side effects, of the use of the chemical into account, 

I am authorized to speak for him, I have outlined for you the 
reasons why he made the decision. Those are the reasons. 

Mr. Wampler. I thank you for saying that. Of course, I think the 
Secretary is the person of whom we should ask these questions for the 
record. 

Mr. Hebbst. I would also point out, concerning your comments on 
the importance of food on the table, that the Secretary certainly agrees 
with that but he has, in addition, other responsibilities, including the 
responsibility for the effects on the environment and the effects on 
other species. So, he does have a balancing role to achieve. 

It is nis opinion that the program has not been hampered and that 
it will continue. We will cariy out the mandate of the AJiimal Dam^ 
Control Act of 1931, but it must be done in a balanced manner. 



D,g,tze:Jb.GOOg[e 



Mr. Wamplbh, That is exactly what I am trying to get at. I think 
that is what most of the witnesses that will appear here are tiying to do. 
We do not thin k y ou are doing that, quite frankly. 

Mr. Hebbst. Well, it is a difference of opinion. 

Mr. Wampler. Absolutely. This committee has a responsibility and 
we are attempting in a reasonable way to find some resolution to this 
problem, and here you are objecting to the enactment of this l^isla- 
tion, as other witnesses are this morning. 

I think it is about time that Congress started directing the bureauc- 
racy to come up with some answers to this problem ana not continue 
to delay workable solutions. 

I do not think there is a reasonable person that would say that 
we can live in an absolutely risk-free society. At some point in time 
we are going to have to start looking at the economic ramifications 
of some of the regulatory decisions that are being made and achieve 
a balance. I think that is what this subcommittee is attempting to do. 

If you are going to come here and oppose everything meaningful 
that we are trying to do, I do not think we are going to reach tnat 
resolution. That is the purpose of these hearings, to try to find some 
ways and methods for reaching a resolution and a solution to these 
very perplexing problems. 

They do not have simple answers. Otherwise, I am sure they would 
have been disposed of. 

That is my point and I hope you Avill give some consideration to the 
economic impact of your dec^ion and what it is doing to the livestock 
sector of this country. 

My purpose in asking you your professional bac^round was not 
intended to embarrass you. I apologize that I did not know. 

From your own recitation, it is obvious that you have had no 
experience in the livestock industry, although 1 assume you have been 
on ranches and farms in carrying out your duties. 

Mr. Hebbst. I appreciate your comments. I commend you on 
trying to find a balanced solution. It is most difficult to do, as you 
well understand. 

We believe that the Secretary has done that. 

As to my background, I do not apologize for it at all. I am very 

firoud of it. In terms of whether or not I have had any experience with 
arming, I can tell you that some of my family does now farm and I 
do own a farm myself. 

I have had personal experience with the animal damage control 
program as a State administrator, both in the timber wolf area and 
in the control of coyotes as well as in the control of gophers, rodents, 
aud niany other species for a number of years. 

Mr. Wampler. I am glad. I again commend you for your recom- 
mendation to the Secretary. I want to publicly do that again as I did 
earlier. I think you recommended policy that is much sounder than 
that which the Secretary finally decided upon. Thank you, Mr. 
Chairman. 

Mr. nB LA Gahza. Mr. Marlenee? 

Mr. Marlenee. Mr. Chairman, I appreciate the opportunity to 
appear here with this committee; although I am not now a member, 
I am an ex-member of this subcommittee. 

Mr. DB LA Garza. We are always hajtpy to have you. 



D,g,tze:Jb.GOOg[e 



60 

Mr. Mablenee. Thank you. I will present some testimony, with 
the chairman's permission. 

Mr. DE LA Garza. That permission has already been granted. 

[The statement of Mr, Marlenee appears on p. 72,] 

Mr. Marlenee. All the flowery language about facing decisiona 
on the basis of scientiflc evidence is somewhat contradictory to the 
statement of the Secretary. Both Guy Connolly, who is with the U.S. 
Fish and Wildlife Service in Denver, and Mr. Greenwalt have recom- 
mended otherwise as far as the use of 1080 is concerned and as far as 
continuing to study it is concerned. 

The Secretary himself said, "I did not accept the recommendation 
of the Fish and Wildlife Service Director, Mr. Greenwalt, to settie 
the question 1080 by an expanded research program." He questioned 
that it would take from 3 to 6 years to answer the crucial questions 
about its safety and efficacy. 

"I believe, however, that compound 1080 is so controversial that 
continuing to study it is a waste of taxpayer's money." That does 
not sound like a decision made on the basis of scientific evidence. 

I am impressed, Mr. Chairman, with the level of the troops that have 
been marshaled against this bill. It is like all of the generals in the war 
in the West seem to be here before this committee, 

Mr. Herbst, I am sure that you do not appreciate, if you do own a 
farm or if you do have a suburban home, the neighbor's d(^ running 
through your yard, digging in the flower bed or relieving its& on your 
trees and shrubbery, and you must concede that the Federal Govern- 
ment does own a great deal of land in the West. Does it not? 

Mr. Herbst. Yes, sir. 

Mr. Marlenee. Do you advocate that the predators that roam this 
vast area of Federal land, 40 percent of my State, be allowed — ^if jyou 
want to term them that, ttiey are your predators — to roam onto nei^- 
bors' land, the State land and the private land, that adjoii^ you? Do 
you have any plans to control these animals? 

Mr. Hehbst. The answer to your question, Mr. Marlenee, was in 
n^ statement. It was that the issue is twofold. One is to maintain the 
bdance of the ecosystem. The other is to control selectively those 
species that are causing the problem, 

I indicated in the conclusion of my stetement that it is the intent of 
the Secretary and the Department to selectively control predators 
where they are causing economic hardship and a problem. We have no 
objection to that. 

Mr. Marlenee. Might I, at this time, read to you a letter from the 
U.S, Department of tne Interior, Bureau of Land Management, to 
Mr. Seyler, who is in charge of the Montana Department of livestock. 
Predator Control Division. 

It says: 

Dear Mn. Seyler: The request by the Montana Department of Livestock for 
aerial hunting of coyotes by Robert Schellinger is not authorized. 

Losses of one calf each, reported by Leonard Urick and Dale Carpenter, do not 
demonstTate a need for control. Of paramount concern to the Bureau are large 
numbeni of mule deer and elk wintering on these areas. Predator control actlvitiea 



D,g,tze:Jb.GOOg[e 



« of a helicopter would cause excessive disturbance of 

ions of enei^y reserves and possible — 

I did not know you were part of the Energy Department — 



Does this sound to you as if you are addressii^ the problem of 
individual predators? 

Mr. Herbst. The 

Mr. Mablenee. Excuse me, Mr. Herbst. This is the kind of thii^ 
that gets to us out there. It really is causing a revolution out in the 
West among people that border public lands and have to use public 
lands. 

This kind of attitude and lack of commonsense is what makes them 
mad when we do want to control some predators. 

The question, to me, does not appear to be simply 1080 but a ques- 
tion of killing any coyotes whatsoever. 

Mr. Hebbst. Congressman Marlenee, the program is to control 
predators where there is a documented loss or a documented problem. 
The record of the Fish and Wildlife Service in the animal damage 
control program has shown an increased number over the past several 
years in the number of animals that have been killed. 

Certainly, there is no attempt to eliminate all of the predators or to 
eliminate predators that are not causing a problem, but there is an 
attempt to focus attention in an environmentally acceptable manner 
and to control those animals that are actually the offenders. 

Mr. Marlenee. Here they have used two very lame excuses. One 
was the natility of the deer and elk populations and I wonder if the 
people that wrote this letter ever considered that coyotes do kill fawn 
and young elk. 

Mr. Herbst. Mr. Marlenee, I am not familiar with that particular 
letter or that particular case, but certainly the Director, myself, and 
staff are aware of the fact that predators kill other forms of wildlife 
just as they do domestic species. 

Mr. Mablenee. Is there any evidence to indicate that the number 
of predators have increased in the West or that predator losses have 
increased? 

Mr. Herbst. I am sure that there are areas of the West where 
predator damage has increased and predator populations have in- 
creased, just as the number of animals that have been taken under the 
control program have increased. 

Mr. Marlenee. Mr. Chairman, my time has expired. 

Mr. DE LA Garza. Mr. Herbst, I appreciate your position. 

As we stated, in order to get the facts in this matter, we are going to 
respectfully invite the Secretary to appear later. 

I did want to ask you a couple of questions since I think you prob- 
ably had some input into the formulation of your statement. One 
Juestion is that you state that the Secretary's decision eliminates 
eoning. Then, there is an utterly unbehevable — you people up there 



db.Google 



are trying to play God, it seems — statement that "when there is 
reasonable assurance that they will starve to death" they will be taken 
out by hand and shot. How you can point with pride to that and con- 
sider it environmentally acceptable is beyond me. 

Mr. Herbst. I think the indiscriminate use of denning when it is not 
needed is what the Secretary has objected to and the bulk of the Ameri- 
can public has objected to. 

The removal of cubs that are starving and the shooting of them is a 
humane removal. 

Mr. DE LA Garza. I do not agree with that, very respectfully. Who 
makes the decision that there is a reasonable assurance that they will 
starve to death? Who makes that decision? 

Mr. Hebbbt. It is the manager or control officer that is responsible 
for the program on the ground. 

Mr. DE LA Garza. On the basis of what criteria does he decide that? 

Mr. Hekbst. The criteria will be developed by the Department and 
published on May 15. 

Mr. DE LA Garza. You say "will be developed," but they have been 
doing it right along. I know of zoos that want them. 

Do you know that the people who are out there complaining, the 
people who are having damage done to their livestock, wiU not shoot a 
pup. I come from that country. 

Yet, you, the saviors, go out and dig them up when somebody says 
they might starve to death. That is not compatible with what you tell 
me, in the rest of the statement, what you are trying to — -not at all. 

Mr. Herbst. Mr. Chairman, it occurs when the female has been 
taken in the control program. The Department is not the savior but is 
the administrator of a program that has been mandated by Congress. 

Mr. DB la Garza. Congress did not mandate at all what you are 
doing out there. You are taking it completely out of the spirit, the 
intent, and the letter of the law. Let us make that clear. 

Mr, Marlenee? 

Mr. Maklenee. Mr. Herbst, you made a statement about himiane- 
ness. Do you consider it humane to see a half dozen sheep running in 
wild disarray, some of them dragging their guts, and others hamstrung? 
Is that humane? 

Mr, Herbst. Of course not. 

Mr. Marlenee. Would your people go out and shoot those sheep? 
Or should some of our people who are trying to raise a flock? 

Mr. Herbst. Sheep are not wild species. 

Mr. Marlenee. They find it almost unbearable to have to go out 
there and shoot their own animals. 

Mr. Herbst. So do I. We are not responsible for the management 
of domestic species. We are responsible for the management of wild 



Mr. DB LA Garza. Do the proposed regulations provide for some 
system for placing the pups in some acceptable place so that they will 
not be preaators if they need to be taken out of the area? 

Mr. Herbst. No, Mr. Chairman, they do not at this point. 

Mr. DE la Garza. I have no further questions of you, Mr. Herbst. 

Are there any further questions for anyone on the panel? 

Mr. Wampler? 



D,g,tze:Jb.GOOg[e 



Mr. Wahpleb. Most of the questioning and comments this morn- 
ing center primarily around the coyote. I assume there are other 
types ofpredators. 

Mr. Greenwalt or Mr. Herbst, can you tell me how prevalent a 
problem of predation there is with the eagle in this regara? 

Mr. Herbst. I will turn it over to the Director for comment, but, 
yes, as I said in my statement, we do have other predator problems — 
rodents, eagles, other predators of all types. We have programs for 
them as well. 

Mr. Wamplbr. My reason for asking you is this. It would be fair 
to say, would it not, that the eagle more nearly approaches an en- 
dangered species than is the case with the coyote? Would that be a 
correct statement? 

Mr. Greenwalt. The bald eagle is rarely a serious problem on 
Hvestock and is an endangered species in most of the United States 
outside of Alaska. The golden eagle, which is the dominant predator 
among the eagles, is not in any situation bordering on threatened or 
endangered at present in the United States. 

Mr. Wampleb. Let me ask you, if you can answer this, smce the 
issuance of the Executive order of 1972, what has happened generally 
to the coyote population? Has it increased and if so, substantially? 

Mr. Gkeenwalt. Coyote populations have done two things. 
Whether it is as the result of the Executive order or not I cannot tell 
you with authority. In some parts of the country the populations have 
mcreased and I suspect, at least at the local level, substantially. 

Coyotes have also enlarged their range so that they are present in 
some numbers in parts of the United States where they were never 
formerly encountered. 

The coyote is a most adaptive and ubiquitous animal. It can survive 
with ease in a variety of aituations. 

I am not prepared to comment categorically on the overall popula- 
tion of coyotes. We do know that the population has increased in 
certain parts of the country and has remamed stable in other parts 
of the country. 

It is subject to fluctuations in accordance with its food base. As I 
said, one of the interesting things that has occurred with this extraor- 
dinary animal is that it has extended its range considerably throughout 
the United States. 

Mr. Wamplbr. As a layman, would it be fair to say that the coyote 
is a rather resourceful, prolific animal? 

Mr, Greenwalt. It is resourceful. If the circumstances are right, 
that is, if it has a strong food base, then it is certainly prolific, as are 
most animals of that kmd, predators in particular. If the food base 
declines, then its reproductive rate declines somewhat as well. 

It is extraordinarily resourceful, Mr. Wampler, and is one of those 
remarkable of nature's creatures who will probably survive when few 
else of us of nature's creatures have survived. 

Mr. Wamplek. Again, this is from a layman's observation. Appar- 
ently, a great deal of the public hue and cry that has been raised about 
the coyote gives the impression that it is going to become an endan- 
gered species or would be a good candidate for an endangered species 



D,g,tze:Jb.GOOg[e 



64 

determination if we had any type of effective predator control pro- 
gram directed at the coyote. 

Would it be fair to say that because of the presence of the coyote 
where traditionally it was not known, it is because we have an effective 
predator control program such that its population has increased and 
it would go into areas where there is not such a proeram? 

Mr. Gbebnwalt, No; I do not think that would be biologically 
sound. However, the coyote, as you pointed out, is extraordmarily 
resourceful and will go where it is appropriate and easy for him to live. 

I am advised that the population of coyotes throughout the coun- 
try, as best we can ascertain it, is about the same as it was in 1972 
but has fluctuated markedly. During the upward fluctuations — in- 
creases in the population — it may well expand its range. 

It does live very readily with man, as I am sure all of you know, 
and so has no problems associatii^ with man and his works. The 
presence of coyotes, in Maine or in West Vii^inia, for example, should 
be no surprise to anyone because coyotes can live in those areas 
very well. 

Mr. Wampleh. Mr. Greenwalt, I know you are here this morning 
in the capacity of a technical witness, not a policy spokesman for the 
Department of the Interior or the Fish and Wudlife Service, but I 
just want to commend you for the recommendation that you made to 
the Secretary, you and your professional associates. 

I have not always agreed with the recommendations of the Fish 
and Wildlife Service on a variety of subjects, but I do commend you 
here because I think that you were making an honest effort to turn 
to the scientific community to try to find an answer to this very 
penilexing, highly emotional problem. 

Again, I feel that if we are ever going to find workable solutions to 
problems of this nature, where else can we turn but to the scientific 
community to provide the answers? They are not without their 
limitations, but I think that is the proper arena to which to submit 
problems of this nature so that they can make a recommendation or 
a simimary of their findings, and then let those who are directly in- 
volved in the regulatory process and the political process, at least, 
give that fair consideration. 

Again, I want to commend you as a professional for the recommen- 
dation that you made. I think you were moving in the right direction. 
At another time, perhaps, we may have the opportunity to discuss 
this with the Secretary of the Interior to see what were the compelling 
reasons that caused him to reverse your recommendation and rtiat of 
Assistant Secretary Herbst, 

I appreciate it very much. 

Mr, Greenwalt. Thank you, sir. 

Mr. DE LA Garza, Mr, Greenwalt, may I ask something con- 
cerning the statement of Mr. Herbst? It says that aerial huntii^ is 
still being carried out. Is that by helicopter or by fixed-wing plane or 
both? 

Mr. Greenwalt. Both, sir. 

Mr, DE la Garza. Have you had any loss of life in that endeavor? 

Mr. Greenwalt. Yes, sir. Quite recently two men lost their lives 
in coyote control with fixed-wing aircraft in New Mexico. 

Mr. DB LA Garza, Is this done by shooting from the air? 

Mr. Greenwalt. That is correct, sir. 



D,g,tze:Jb.GOOg[e 



65 

Mr, DE LA Garza. Is it done by high velocity bullet? 

Mr. Greenwalt. No, sir. It is usually done with a shotgun. 

Mr. DE LA Garza. That means that the plane has to be less than 
50 yards from the target. Is that correct? 

Mr. Greenwalt. It is a relatively low altitude, in this case, less 
than 100 feet, sir. 

Mr. DE LA Garza. Sometimes this occurs in relatively mountainous 
and ringed terrain, does it not? 

Mr. Greenwalt. We usually do not permit fixed-win{j aircraft to 
operate in mountainous terrain. The accident, to which I refer, 
occurred in rolling hills with some brushy terrain. 

Mr. DB LA Garza. When you mention trapping, do you mean steel 
claw traps? What kind of trapping do you mean? 

Mr. Greenwalt. The steel-jawed trap is the one most often used 
in predator control, particularly where coyotes are concerned, although 
the Service and others do use snares and other devices. 

Mr. DB la Garza. What are the criteria for placing the traps? 

Mr. Greenwalt, I am not sure I comprehend precisely what you 
mean, Mr. Chairman. 

Mr. DB LA Gakza. Where do you place them and how? 

Mr. Greenwalt. The fundamental effort, and one that can be made 
with extraordinary effectiveness by a good trapper, is to place the trap 
in such a way that it will take the animal that is likely to be affecting 
a herd. 

Let me explain quickly that a trapper with reasonable training and 
a certain amount of experience can identify with, as I say, remarkable 
accuracy where the coyotes are approaching a herd of sheep or goats 
and can place traps in such a way that most probably it will take an 
offending animal, a coyote, as opposed to, say, a cow wandering by. 
The animal causing the problem is very quickly removed. 

Mr. DE LA Garza. That means that the professional trapper wants 
to be selective and t*> get only the offending animal. Is that correct? 

Mr. Greenwalt. The professional trapper is instructed to be 
selective and to, insofar as possible, get the animal that is in fact 
affecting the herd. 

Mr. DE LA Garza. So, what we need is a system that would be quite 
selective and environmentally acceptable. Is that right? 

Mr. Greenwalt. That is absolutely correct, sir. 

Mr. DE LA Gakza. When you speak of trapping, the M-44, and 
aerial hunting, is that on private and public lands, or only on public 
Ifmds? 

Mr. Greenwalt. The involvement of the Fish and Wildlife Service 
means that the use of aerial hunting, the M-44, and steel traps is 
applied both to private and public lands, insofar as Federal involve- 
ment is concerned. 

Mr. DE LA Gahza. What is the Federal involvement on private lands 
as far as financing aerial shooting of predators is concerned? 

Mr. Greenwalt. Federal financing is supplemented in most States 
by assessments made against the herd, or taxes imposed by the county, 
or funds made available by the State involved, that provide for an 
enlarged and expanded program based primarily on tue idea of the 
growers making a contribution to the basic Federal program. 



D,g,tze:Jb.GOOg[e 



66 

Mr. DB LA Garza. Is this done at the request of the landowners atall 
times, or are there exceptions? 

Mr. Gheenwalt. Do you mean, in terras of payment? 

Mr. DE LA Garza. I am asking about aerial hunting? 

Mr. Grbbnwalt. It is done at the request of the landowner involved. 
The Service does not, as a practice, cany out a control program on 
private lands when the landowner is not desirous of having that kind 
of work done. 

Mr. DB LA Garza. When is it done on public lands? 

Mr. Grebnwalt. It is done on public lands at the approval of the 
public land manager and when there is a request by the land user, the 
grazer, that some predator control action be undertaken. 

Mr. DB LA Garza. Thank you very much. 

Mr. Jellinek, since you have given testimony with respect to 1080, 
does the EPA have an acceptable substitute that would have the same 
effects as lOSO? 

Mr. Jellinek, Mr. Chairman, there are no predicide toxicants 
registered for use against coyotes with the exception of the aodium 
cyanide M-44 device. 

Mr. DE La Garza. Do you have any research of your own? 

Mr. Jellinek. We are not sponsonng research. That is the responsi- 
bility of the other departments at the table this morning. However, we 
do cooperate with them or with State researchers in the development 
of criteria for research so that if the research should turn out significant 
new evidence we would be able to incorporate that evidence mto any 
future regulatory proceedings. 

Mr. DE La Garza. Is it the position of EPA at this time that they 
would be willing to consider continued research on this substfmce by 
the States or by special permit to individuals or States? 

Mr, Jellinek, As with any pesticide situation, we would be willing 
to consider and to consult with those who are interested in developing 
research and experimental use permits to jjroduce information that 
might be used in future EPA regulatory decisions. 

We have a history of having done this in many areas and we make 
our decisions based on the evidence that is developed. We have 
generally been open to working with those who are interested in 
experiments and m research if we believe that there is a reasonable 
chance of developii^^ significant data, 

Mr, DE LA Garza. Are you talking about a purely scientific 
viewpoint? 

Mr. Jellinek. That is correct. I am talking about a purely scientific 
viewpoint and from our ownjudgment as to whether the study that is 
proposed has any scientific chance of coming up with adequate infor- 
mation. We would not and have not participated in research programs 
that we do not think have much of a chance of developing significant 
information. 

Mr. DE LA Garza. That would be a personal or a collective judg- 
ment within the t^ency, but what I am trying to get at is that your 
permission for continued research would be based solely, aside from 
the long-term expectation of what the expenditure would be, on a 
scientific stand. Is that correct? 

Mr. Jellinek. It is primarily a scientific decision. Our scientists 
advise us on the scientific aspects of the proposed research. 



D,g,tze:Jb.GOOg[e 



67 

Of course, we are also concerned that the research can be conducted 
in a way that does not result in misuse of the research chemical and 
that the research itself does not create an unreasonable adverse risk 
to health or to the environment. 

Mr. DB LA Garza. Thank you very much, sir. 

I think it was in your statement, Mr. Herbst — not as a question 
but as a statement, concerning the fact that you say 1080 would never 
be acceptable to a majority of society. I challenge that statement. 

R^ardless of your qualifications as an expert m this field, I do not 
consider that you would be an expert on what the majority in the 
United States might do. 

Further, I take it as a personal affront to me that you say, "since 
this legislation does not consider the adverse impact on wildlife 
resources or the environment," 

Thank you very much. We appreciate your being here. 

Mr. Wamplbr. Mr. Chairman, I have one brief question, if I may 
pose it. 

Mr. DB LA Garza. Yes, Mr. Wampler. 

Mr. Wampleh. Mr. Jellinek, as I recall, this committee requested 
of the Enviromnental Protection Agency the development and sub- 
mission of the list of pests that could and should be brought under 
control. Has your department completed its work on this yet? My 
recollection is that it has not been submitted. 

Mr. Jbllinek. I will have to defer to Mr. Johnson to answer that 
question. 

Mr, Johnson. No, Mr. Wampler, we have not yet completed our 
work. We have a cooperative program uiider way right now with the 
U.S, Department of Agriculture and the State extension and co- 
operative research people. We expect some of our first outputs in 
approximately the next 3 months. They will deal with several major 
crops. We will be adding to that as we proceed. 

Mr. Wamplek. Will predators be added to that list? Would you 
classify a predator as a pest? 

Mr, Jellinek. Yes; it is a pest under the FIFRA and we are looking 
at the livestock industry as one crop production for which we will be 
developing a pest list. 

Mr. Wamplbb. Than, a coyote would be a potential candidate for 
your hst of pests. Is that correct? 

Mr. Jellinek. That is correct. 

Mr. Wampler, Thank you. 

Mr, Chairman, I have one final thing. I would like to read into the 
record a communication from the President of the United States. 
This was printed in House Document No. 95-60, of the 95th Congress, 
1st session. It is very brief but I think it is appropriate to our hearing 
today. 

It is from : 

The White House, Washington, January 19, 1977. 

It is addressed to : 

Hon. Thomas P, O'Neill, Jr., Speaker of the House of Representatives, Wash- 
incton, D.C. 

D«ar Mr. Speaker: Each jrear animal predators destroy large numbers of live- 
stock in many areas of the Nation. Sheep are especially vuhterable to kills by 
coyotes. 



D,g,tze:Jb.GOOg[e 



Since 1931 the Federal Government has assumed a degree of responsibility of 
controlling animal predation — on both public and fjrivate lands. This function 
was originally established in the Department of Agriculture, then transferred to 
the Department of Interior in 1941. 

I believe that it is now appropriate to return this function — except the migra- 
tory bird control — to the Department of Agriculture. Accordingly, 1 am herewith 
transmitting the necessary reorganization bill. 

This legislation would reestablish most of the animal damage control activities 
of the Federal Government in the Department generally responsible for protecting 
the Nation's crops and livestock from various forms of damage — the Department 
of Agriculture. That Department already conducts predator research. It is close 
to the Nation's farmers and ranchers. At the same time, the Fish and Wildlife 
Service of the Department of the Interior will be relieved of a function at times 
inconsistent with its broader objective of protecting and enhancing the wildlife 
resources of the Nation. 

I am committed to solving the predator problem by environmentally acceptable 
means. Increased research will be devoted by the Department of Agriculture to 
selective and humane ways of dealing with predators. Control activities will con- 
tinue to be regulated under the Federal Insecticide, Fungicide, and Rodenticide 
Act, as administered by the Environmental Protection Agency. 

No additional budget outlays would be required as a result of this proposed 
legislation. 

An identical letter has been transmitted to the President of the Senate. Sincerely, 
Gerald R. Ford. 

[Enclosure.] 

Mr. Chairman, along with this Executive communication came a 

froposed bill to transfer certain functions from the Secretary of the 
nterior to the Secretary of Agriculture. Unfortunately, the bill did 
not become law. Had it done so, perhaps we would have made more 
progress than we have to date in trying to solve the predator problem. 

I just want to say again that I appreciate each of the witnesses 
appearing here. If my blood pressure appeared to be above normal, 
let me assure you that it was and still is, but I want to work with 
you in any way possible. 

When you come here and oppose what we perceive as being an 
honest and sincere effort to find workable answers, taking into account 
a number of factors, then it causes our blood pressures to rise above 
normal. 

I assure you that I am looking for workable answers and solutions. 
We want to continue to work with you in a cooperative way. 

Thank you, Mr. Chairman. 

Mr. DE LA Gahza. Thank you very much, gentlemen- 

We are running a little bit ahead of schedule and we have some 
problems with respect to airplane schedules, and so on, so I am going 
to assume the privilege of allowing to testify at this time our colleague 
from Montana, Mr. Marienee, and then we will accomodate the Secre- 
tary of Agriculture of the State of the State of Texas who has an early 
plane to catch and anyone else on the list of today's witnesses that 
may have a problem with transportation. 

Mr. Marienee? 

STATEMENT OF HOH. BON SARLENEE, A BEFBESENTATITE IN 
CONOBESS FBOH TEE STATE OF MONTANA 

Mr. Marlenee. Mr. Chairman, I ask unanimous consent to insert 
into the record my full text and all attachments thereto. 
Mr. DB LA Garza. That permission has already been given. 
[The statement of Mr. Marienee with attachments appears on p. 72.] 



D,g,tze:Jb.GOOg[e 



Mr. Mablgneei. Mr. Chairman, 1 commend you and the committee 
for holding these hearings and request that you add my name as a 
cosponsor of this bill. 

It is very apparent that the Secretary of the Interior intends to 
discourage the control of predators on pubUc lands. 

It is apparent that public sentiment, conunonsense, good judgment, 
and consideration of ttie neighbors of public lands are very low on the 
priority scale in the management of predators and, for that matter, 
public lands. When faced with such decisions, we as elected represen- 
tatives have very little choice but to pass legislation of the type under 
consideration. 

First, I would like to submit for the record, a letter received by the 
Montana Department of Livestock. The letter demonstrates the lack 
of commonsense and consideration that is encouraged by the Secretary. 
It indicates that 1080 is not the real problem out simply that no 
control of predators is the issue. 

Mr. DB LA Gabza That letter has already been entered into the 
record by Mr. Wampler and appears on page 52. 

Of course, we will be entirely happy to have you as a cosponsor of 
the bill. 

Mr. Marleneg. I believe the response from your own State depart- 
ment of hvestock demonstrates how ridiculous the situation has 
become. 

The letter from the Department of the Interior was to Ken Seyler, 
who is chief of pest control in the department of livestock in Mon- 
tana. You heard it read by Mr. Wampler. 

This is certainly not a letter that used a lot of common sense or 
practical experience, as was demonstrated by the reply that the 
DOTtartment of Livestock, State of Montana, made to that letter. 

I will read from the reply : 

No. 1; 

The lands involved are checkerboarded private, state, and BLM. The llveatook 
losses on the two ranches shoiUd be recognized as six calves and five sheep. Per- 
mission for aerial hunting on the private and state lands in question has be^ 
approved. 

No. 2; 



No. 3: 

Your statement that use of a helicopter for aerial hunting in this area would 
cause excessive disturbance of big game, resulting in depletions of energy reserves 
and possible reduction of natality is nonsensel We operate three helicopters in 
our department for animal damage control and know from firsthand experience 
deer and elk do not stampede or run from helicopters when appropriate aerial 
hunting is conducted. Mr. Schellinger flies for U.S. Fish and Wildlife Service on 
a contract basis for animal damage control and experiences this type of flying 
regularly. Additionally, if you are worried about nataUty reduction, a few less 
coyotes in the immediate area may increase the fawn production more than most 
wildlife textbooks may lead you to beheve. Besides, we thought the State Depart- 
ment of Fish, Wildlife, and Parks [sic] had jurisdiction over wildlife— related 
materials. 

The whole thing boils down to one fact, does the BLM want to be a good 
neighbor or not? For the ranchers involved, you are affecting their pocketbooks 
by not allowing assistance with this coyote problem. 

Additionally, whatever your decision, aircraft at any time can fly over these 
BLM lands within 500 feet of wildlife and not violate any state or federal fljing 



D,g,tze:Jb.GOOg[e 



70 

laws. Is Bnowmobiling, hiking,_ backpacking, cross-country skiing, and all other 
foims of activities also denied in these areas? 

That was from Ken SeyJer. 

The actions of the Secretary have left the wool growers with few 
options to control the predator damage to their herds. Financial 
losses to the sheep industry have continually climbed over the years 
imtil they reached close to $1 billion in 1978. 

SecretaiT Andnis' a«tions are sure to make this figure much hieher. 
It is also obvious that the Secretary does not coim)r^eud the ;^^lem 
of predator damage and has ignored the advice of those in his Depart- 
ment, despite what may have been said here this morning by the 
generals that were marshalled here before us. 

Mr. Guy ConnoUy, who had directed the 1080 toxic collar program 
and is with the Fish and Wildlife Service in Denver, said the only 
thing wrong with 1080 seems to be that it is a poison with "a very 
adverse political history." 

I would like to quote from the 1964 report by the Interior Depart- 
ment on Wildlife Management for States : 

If regulations for the placement and treatment of 1080 stations are strictly 
followed, we agree with the Branch of Predator and Rodent Control that it is 
perhaps the most efficient and one of the least damaging methods of coyote 
control on open lands of the western United States. There are a few otjier areas the 
Secretary has ignored in hi» decision making. 

In the 1976 Federal Register the EPA noted: 

The Agency has no valid evidence that the use of 1080 and 1081 have actually 
resulted in tlie deaths of members of the endangered species (vol. 41, No. 232). 

The Sheep Producer Environmentalist Council has stated that: 

No one method is a panacea for oroteotion of Livestock. The animal damage 
control program must include a wide variety of methods, lethal and nonlethal, 
applied under careful supervision as specific circumstances dictate. Research 
must continue to be supported. Not only does this group support additional re- 
search but ao does the Director of Fish and Wildlife, Mr. Greenwalt. 

I have attached a letter from the Secretary indicating Mr. 
Greenwalt's position and the decision by the Secretary not to continue 
research into compound 1080. 

What mav interest members is the statement by Mr. Andms' that, 
"Compound. 1080 is so controversial that continuing to study its use 
is a waste of taxpt^ers' money," 

Mr. Chairman, I thought, that the job of bureaucracy was to help 
to clarify controversial issues and not to instigate them or let them 
hang in the air. 

Let us look at the cost of not approving 1080. A 1974 report by 
USDA stated that predation on sheep, primarily by coyotes, cost the 
consumer an additional $10 milhon throi^ higher prices. The industry 
cannot continue to suffer such losses and remain in existence. 

The sheep growers need assistance in controlling predators. The 
unacceptable loss phrase used by the Secretary is a misnomer. Losses 
have been unacceptable for years and the Interior Department has 
done little, if anything, to correct the situation. Now, they are going to 
do even less. 

An industry which contributes milhons to the Nation should not 
be forced into continual losses due to the actions of a Cabinet member, 
especially when the action flies in the face of others within the Interior 
Department, the wood growers, and the consumers. 



D,g,tze:Jb.GOOg[e 



71 

I would like to point out to the members that the Interior Depart- 
ment has suggested nonlethal techniques to control predator losses. 
These techniques include additional uses of herders but in a letter re- 
ceived by the Department of Labor, which is attached to my testimony, 
you will note that the Department of Labor will soon rule that herders 
must be given an opportunity to return to their native countries at 
the expense of the owner of the herd. 

This additional cost will further reduce the income of the wool 
grower, wiU make it harder to maintain herders and to keep herders. 
It also shows how two agencies within our Government work m opposi- 
tion to ea«h other. 

The current practice which has been in effect since the 1950's give 
the herders an opportuni'hr to return home at owners' expense at the 
end of a 3-year contract. The practice will no longer be legal. 

WhUe this problem is outside the scope of the l^^lation, I certainly 
think it has some ramifications for the passage of the legislation. I think 
the subject should be pursued. 

I would like to thank the members for allowing me to present this 
testimony. 

[The prepared statement of Mr, Marlenee follows:] 



D,g,tze:Jb.GOOg[e 



STATEMENT OF BON. ROH KHSLENEE, A UPRESEHTATIVI I> OMQtEBS 
FROM THE STATE OF MONTANA 

Hr. Chaltman, It ia a pleaaur* to appaai bafora tha Subconoittee. 

A3 an ex-Riember of the Subconnittee , I know hov connnltteil each one of 
you is to promoting agriculture. I will addreaa ny teitlnony to 
H.R. E725 and the cecent changes In the Animal Damage Control 
program as envisioned by Secretary Andrus. I commend the Chairman 
of the Subcommittee for holding theae hearings and his sponaoxihip of 
this legislation. If the members will permit, I would alao like to 
briefly discuss an issue whldi is diractly related to the l^ss of 
aheep to predators but not addressed in the legislation before the 
Subconmi t tee . 

It is apparent that the actions tahen by the Secretary will 
increase the nunber of livestock loat to predation, increaie the coat 
of livestock products to the consumer, and provide little if any 
benefit to anyone but the coyote. 

The actions by the Secretary have left the woolgrower* with 
few options to control the predator damage to his herd. Financial 
loss to the aheep industry have continually climbed over the yeaxB 
until they reached close to 1 billion dollars in 1978. Secretary 
Xndrua* actions are sore to make this figure much higher. 

It ia obvious that the Secretary does not comprehend the 
problems of the predator damage and has ignored the advice of thoss In 
his department that are the moat knowledgable about the subject. 1 
have attached a news article from a Hontana paper which quote* Flah 
and Wildlife employees as distressed over the actions by the 
Secretary. Mr. Guy Connolly, who has directed the lOSO toxic collar 
program and is with the r t M service in Denver, said the only thing 
wrong with 1080 seems to be that it la a poison with 'a very 
adverse political history." I would also like to quota from a 
1964 report by the Interior Department on Wildlife management lAicb 
states 'If regulations lor the placement and treatment of 1080 
stations are strictly followed, we agree with PABC (Branch of 
Predator and Rodent Control) that it la perhaps the most efficient 
and one of the least damaging methods of coyote control on c^en 



D,B,i..ab,Google 



lands ol the weHtern United States. There are a few other areas the 
Secretary has ignored in hia decision making. * In the 1976 Federal 
Register, the EPA noted "the Agency has no validated evidence that 
the use of lOBO and 1D81 have actually resulted in the deaths of 
■a^Mrs of endangered species.' (Vol. 41, No. 232} 

Thia leads to the question of the stand taken by environmental 
groups. While I know that many such groups will preaent testinony 
to the cc»aittee, and I in no way want to prejudice their position, 
I think that the reaction by two western enviromnental groups would 

Bill Cunningham, Montana Representative of the Wilderness Society, 
told Eheepmen that his organiiation had nothing to do with Andrus' 
policy on predator controls. Cunninghan said conuDercial grazing 
ia c^qiatible with wilderness in most cases, and where it is not, 
perhaps wilderness designation should not be sought. 

The Sheep Producer/Envirxuuaantalist Committee haa stated that 
'no one method la a panacea tor the protection of livestock. The 
Animal Damage Control program must include a wide variety of methods, 
lethal and nonlethal. applied under careful supervision, as 
■pcctf ic circumstances dictate. Research must be continued to be 
(i^iported.* Hot only does this group support additional research, but 
bo dues the Director of Fish and wildlife, Mr. Greenwalt. I have 
attached a letter from th^ Secretary indicating Hr. Greenwalt' s 
position and the decision by the Secretary not to continue research 
into cofqiound 1080. Nhat may interest Dtenbers is the statement by 
Andrua that 'confound lOSO is so controversial that continuing to 
study It is a waste Of taxpayers' money.* I thought the job of 
government was to help clarlQ controversial issues, not instigate 
the> and let them hang. 

Lets look at the coat of not approving the uae of 1080. A 
1974 report by the USDA stated that predatation on sheep, a majority 
by coyotes, coat the consumer an additional SIO million through higher 

In the saae year, the costs to the sheep industry were approximately 
4G.9 million. Attached you will find a table, supplied by the 



D,g,tze:Jb.GOOg[e 



National Hoolgrowera , which indicate! the dollar loaa auf farad by 
the sheep Industry. In my state of Montana, loasea in 197S amounted 
to over a atagaring 10.9 million dollars. This la trtm a total 
value of shaep for that year of 43.2 million. The estimated loss to 
conaumers is $98 ■llllon. Or put another way, the Bmoont of lamb 
lost to predators In 197B would have fed 220 million JtmarScans foe 
32 days in the year. ,.. 

In B study at Florence, Montana, conducted by the Denver 
Wildlife Research Center, U.S. Fish and Wildlife Service, Hontena 
Department of Fish and Gama, University of Montana, and the 
Hildlifa Hanagement Institute Cooperation, concluded that coyote 
predatation was the primary cause of shaep leases, and predators killed 
more than 16 percent of the flock each year (over the two year 
study period) for a total of 1,027 sheep. Coyotes were responsible 
for 97.1 (first year) and 99.3 (second year) of all predatlon. 
Secondary loBsea, resulting from harassment by coyotes. Included 
reduced lambing success, increased excitability of flodis, reduced 
growths rates and difficulty in fattening lambs, and loss of unborn 
Ismbs. 

The industry cannot continue to suffer such losses and remain 
in existence. The sheepgrower needs assistance in controlling 
predators. The "unacceptable loss" phrase as used by the Secretary 
ia a Biisnoner. Losses have been unacceptable for years, and the 
Interior Department has done little to correct the situation. 
And now, they are going to do even less. An industry which contributes 
millions to the nation should not be forced Into continual loss due 
to the actions of a Cabinet Benber— especially when the action flics 
in the face of others within the Intsclor Department, the woolgxower. 



I would like to point out to members that the Interior DepeitMent 
has suggested non-lethal techniques to contxol predator 4olses. These 
techniques Include additional ua« of herders. But in a latter raoaiT^^ 
from the Department of Labor (attached) you will note that the DOL 
will soon rule that herders must be given tbe o^^ortunl^ to return 
to their native countries at the expense of the owner of the herd, ms 



D,g,tze:Jb.GOOg[e 



additional coat vill further reduce the Inccone of the woolgrower. It 
also ehows how two agenciea work in opposition to each other. The 
current practice, vhich has bean in effect since the 1950's, gives 
the herder the opportunity to return hone, at the dHners' expense, at 
the end of the three-year contract. This practice will no longer be 
legal. Mhile this pitibltaa ia out of the scope of the legislation 
before the subconndttea , I think that the subject should be pursued. 
I would like to thank the inaidjers tor allowing me to present this 
teatimmy . 



t-eo preduv. . coniioii^itt-; 
upset with new policies^^/ 



I «bi»l la nplaB Andns' n 



D,B,i..ab,Google 



United States Department of the Interior 



Honorabla Sat Marlence FEB 1 • «»> 

Hatme of ]l«{ireKiitsti¥ef "W 

V.'oshlnslon, D.C. 2051S 

DeiT tir. Markneei 

niank you for your letter of Dccemb^ IT about my reecnt declfloni eanccmfag 
the Animal Damage Control (ADC] FroerBm. I apcreclate this cppcrtunlty to 

cicrify some mlaunderstendingi about my directives. 

First, I would Itke to point out that the only Immediate actions resulting from my 
November dedtlora are emOng T e^ earrti on compound t08D Bud proMbitliiK Fodiral 
employees from the [raetlca of deimhc — kllUne coyote piva- ki Ow dan. 

I dM not accept the reeommaiAdloD of FWi and WfldUfe Service I 
GreenwaM to settle the iiuestloD of eompoind 1089 by an eipaiidad r 
prograia. He estimated that It mudd talte ttom three to n*e yean to answer me 
cractal quealloM about it* safe^ and «fncaey. I beUcv«, bowevor, that eompomd 
IDBB b BD controverclal that contta^iK to study H Is a waste xit the taxpayM^ 
money. Even It it were to be tentaUvdy appKive<% then almost certain^' K woidd 
be subject to long and costly litigation. biMaac^ Ke Aould devote oar raienreh 
fumb to sedcbv a substance which Is effective and cnvfronmoital^ aceeptablo. 

Denning aceounta for only a small fraction of the coyotes IdUed In the Animal 
Damsge Ccntrol Progam, yet It la e pvetlea which is rcfiulshre to the mftjority of 
Americans. I believe Its prohibilEon win have mlnlmali If ai^. Impact on Uvestodc 
loses and will make the Federal program more accept^de to the publls. 

V;hlle present control methods — aerial hmttng, trtppitg, and the U-41— win 
continue, I have directed that they be ued as seketivdy s« por^stble. I have alas 
dirccttd that the Flah end WDdUfe Service emphasise and encourage the ise ^ 
nonlcthal controls to the degree i»^ctieal now, and. focus Its research efforts en 
lliem I'ith the long-term goA of mlnlmlEfa« the use of lethal eontrc^ Konlethal 
methods will have to be proved effeottv* and acceptable before we move to 
ImplemcntiUon. The Fish end HlldUle Bervloe Is develOfdoE criteria for defining 
■offendine animals" and 'unaaeeptsl^ leveV of bsaes, a* well as prooedures lor 
documenting those losses and epilog preventive ocntnflt. 



D,B,i..ab,Google 



It should be cmphaabccd that nothtng In my doelBlan prohlblta rnncbera end herders 
from cErryinK out private ptedator control actl^tles where there It no conflict 
r.ith state end Federal bws already In «[fecl. The new Federal policy cppUes to 
control ot pfcdalors on Peceral raiigelEnds by Federal employee* or predator 
contrcl actlvitlci undcrlaken with the assistance of Federal fundh 

The predntor control controversy has been iiround for s long time end nfU remotn 
in Ifie future. What I am trying to <io during my ElcwrjdsTilp as Secretary ot the 
frilerior Is to eliminate the emotional fingei-pointing tnd remove predators Irom 
those oretia where they tnfUct unacceptable damage to liveitodc, xithout attempt- 
ing to declare nar on all coyotes. To do this, we have to look at both loivterni 
end ihort-terni lolullon. Soaewhere b*tw«ai those who do not want any eoyotaa 
kOtod and thoae who would IDoe to eUinkista the ipedei entirely, I thiidt thai there 
are reasonable lolutlaiia and flwt, witii your eentbndns advice and ooopenUoB, i«a 
can fbid them. Cf * ' 

1 am attaching vagie* of mj declaion memorandum and a recent ^Medi I pve, 
which explain my declaton b) detalL If you need further hformatkn, pleeae let dm 

Sbteerely, 
BBCRETABY 



db.Google 



AGItlCULTORB/Iiiran toch 
abaap- labor 



c I^ui.onbla Ray Huihall 
crolcry of Lrhor 
,.;.-u :,.t at Lilor 



IL haa CODE Es 07 attmClm chat tha ECiplojiiwDt «d Trainlni AdBlalatcaElon 
iDIenilc SJOB to iaaua nau gujdallaaa uhlch would raqulre cha BBpIoyar to olfac 
tlia hGiil^r cetuis trasapncutlon rltcr onlf 11 lAntha of amploynant . 1^ ttiia 
cLjnic. '.alfcoucT* nould Iie clfcctlvdlr JoprlvxJ of cheli cElltlnG clS^'t to 
ctotriict :JlLh Coralia hardata 6or tlirea ytira of cnploycant. 

Tlili eh£a^a vouU ii^oae al)(iilfleaiiC haidahlp on the shaep Induatr^r and crcata 
bi[:h«r pilcca to tba conmatr. It la additionally tToubllsv that this changa 
la CDntcB^latail to b* ■nsoimGad Jiiat pilot to tha onaot ot the laAloi cDSton 
uhcD tha naod for bocdara la critical. I do not undBtatBiid tha Taaaon for a 
cb«DEa HJilch vdbU ba contrazy to cha adEilnlatratlva pEBCtle* folliMad by yauE 
UcpaftEont alnca tba USO'a. The piopoacd chaDge uould alao apparently craota 
a condition iDconaiatant vltb botb tha aplclt and tha laCtai of tha IioiletBllDB 
and i^mionallCy Aet-ani! Ita related re^ulatlona. 

Since th^ L<:i.^rtuenE of lucailoT, Is ttaalt raalrueturlos of tba Anloal Danga 
Coiitcol i'roi;c^i:, baa aupported Ecd enEoucngad the iddttlenal uta of aheaphetdara . 
tha poaiclon of your department la even core difficult to eo^rebacdi 

i;ith th.'SL- cuneama la Bind, I aak Unit you not laaue theae guldellnoa. I i«uld 
cprrcd^tn lirailDS som fron your ofClcf or the ii^iloycant and Iialulns AdulnlEtr 
tlon GO th^t I dcht have on cxplanstlou of thla proposal and hear tha raaaoBa wu 
aucb a cbanga la being conteiuplatad* 



D,B,i..ab,Google 



U.S- DEPARTMENT OF LABOR 



m 



HSk yoa for your letter of rebimrj 15, I98O. to the Secretary of I*bor 
meernlng ihn DepartneEt'a plkDE to leiue otv guidelines Tor proceselng 
iplicBtioDB for EheepherderE under regulBtioDS aoverning labor certlfi- 

ferred /our letter to this afflce for reply. 

'^ueatB for tenporary forelgii she^Aerdere. Tbe euidellnee vere developed 

i« inajorltir of wool grosera who i^ort iheepherdera . Aereement has_littir 
acbed on all proTi»Ion» of the gnldellBea with respect to the procedure* 

eepherdera. Tbt Deportnent ia alao including In tbeae guidellnea a 

Icti requires employera or temporary foreign worJeers to provide return 
ansportation to foreign vorkere npon coopletion of their contract. 



GcaipletlDB of 
Tbe Depu-taeat 

unnececaary delay in naming determinatioDH. 

The lnr.igrKtloa and Bationellty Act (HA) providea for the aduiBBloa of 

haala dependlOB on the nature of their eaployment. A foreign worker 

certification under Departaeot of labor regulationa at 20 CFB 656 and. nay 
then petition the luaigration and lataraliution Serrice (INS] for a 



cltlienshlp including t 



D,g,tze:Jb.GOOg[e 



An alien comlac ^° this countr/ to perfom totporBry ficrleultural labor BUit 
secure Ibhor certlflcatioo -undar regul&tlon* at SO CPR 6$; and Bay tben 'be 
admitted -under the "H-^" provision -of tbe HA. TemporaiTf vorkera nay be 
erantcd S-£ vIebb "by tbe nS for periods not to exceed 1 year. Such vlaaa 
aay vith nev labor certificationa "be eitended twice alloying the alien 
an unbroken stay in thlB country Tor A naximua of 3 yeara. An alien vith 
an H-S visa aay remain in the country only so long as he ia ^ployed ty the 
enployer vho sponaored hta adoiaeion. 

In 19ST, the Houee Judiciary Coinilttee, recosniiing that sheepherdlng Is a 
permanent cupsitiun tut concerned over the- high -turnover of foreign herders, 
recoraraenaed that £hc-tpherderE be admitUd under the H-2 proviaions of tbe 
IHA (House Report No ^T Bjth Congress, Ist SesElon) The Department has 
been guided by this reCDnoEndation of the Committee and has been proceasing 
reguests lor eheepberderB under Its "teuporary" resulatlone at 20 CFR 655. 
It should be noted that the Department also processes requests for sha«p- 
herders under the 6^6 (penHnent) regulations and ofteo receives such 
requests from the WHA Tor herders «ho have been in H-2 EtatusjffV ^ years. 
The employer of aheepherdera has, therefore, the option to request certifi- 
cation under the "permanent'' regujatlonp vbich have Oo reqiiireaent for the ^^ 
eaipltqrer to provide transjortation. 

Vhen herders are requeated under its "teatporary" regulationa, it ia tbe 
legal obligation of the Department to require conplionce irith tbe 
proviBions of those regulations. All employers of foremen teaporary 
agricultural vorkers must provide return transportation by the end of the 
certification period. In Its new guldelinea, the Department reiuiree that 
return transportation muat be offered to the foreign herder after 11 months, 
but allowing for recertification and visa extension does not require that 
it he paid until tenilnation of employment. It ia the position of tbe 
Department that retention of a work force, either domestic or foreign. Is 
the responsibility of the mployer and nay be Bccomplished by proTldtng 
adequate vages and working conditions. Foreign herders on K-2 visas 
should not bo Induced to stay oo the Job by the vithholdlng of a benefit 
which under the Departnenfa regulations Has been earned after U ■onths. 



f you have further questlona 



a tbiB oatter. 



DAVID 0. UILLIAMS 

Admlnlatrator 

U.S. Baployaeot Service 



D,g,tze:Jb.GOOg[e 



1958 
1959 
1960 



lioi 

1125 



1963 


1581 


196* 


1553 


196S 


1503 


1966 


1387 


1967 


13S1 


ises 


1250 


1969 


U78 


1970 : 


1113 


1971 ! 


i067 



3033 

3618 
A02B 



3736 

3240 
3630 



37tB 
6377 

4745 



D,g,tze:Jb.GOOg[e 



klltid if prediter* InvtntOTT plua pradicor 1 
r*:: ' Isab crop 
(1000) (I) (tlOOO) 

■ Vnit.d Sl»;«i « 

1950 15&6 ., i.QO 31,6S1 

»5) 1708 4.0« . - 2S,017 

1960 .L9SB '4. J] 28,405 

1961 1^04 t.il 1«,BSB 
' '1962 1S43 «.&9 26,9*7 

1963 1790 «.Se 26.025 

196* 1651 4. SI _27.&11 

1965 ISOS &.36 31,766 

1966 1676 

1967 , 1696 

1968 1SS3 ■ 

1969 1439 

1970 1«3I 

1971 1549 
1971 1623 
19T3 156S f 
197* 149)/ 

19J5 is:5 

1976 1362 

1977' 1382 

1978 1321 



4.94 


35.452 


5.19 


31,302 


4.81 


*0.1S3 


4.64 


37.341 


4. 68 


36.178 


S.28 


J6.907 


S.6S 


' 42,933 


5.63 


52,411 


5.74 


*£,»09 


6.57 


57.566 


6.45 


• S8.B03- 


6.83. 


72,377 


6.68 


97,819 



D,B,i..ab,Google 



Mr. DE LA Garza. Thank you very much. 

Our next witness is Hon. Re^au V. Brown, commissioner of 
agriculture of the State of Texas, who will also be making a presenta- 
tion on behalf of the Governor of the State of Texas. 

Commissioner Brown, we are happy to have you here. 

Mr. Wampler. I would like to add my word of welcome to Mr. 
Brown. 

Mr. Chairman, this is a fact that I hope that you and other Texans 
are aware of. Mr. Brown's reputation as an able administrator and 
as one who is knowledgeable in agriculture extends far beyond the 
borders of Texas. 

We appreciate the many contributions that he has made and we 
are vitally interested in what he has to say today. 

STATEHEHT OP BEA0A5 V. BBOWH, COHHISSIOREIl OF AaEICXOr 
TUBE, STATE OF TEXAS, KEFKESEHTIHO SOVEKNOB CLEUERTS 

Mr. Brown. Thank you, Coi^ressman. 

I am delighted to be here as the commissioner of agriculture from 
Texas and to appear before this distinguished committee chaired by 
one of the finest Congressmen we have from our State. 

Congressman, if your blood boiled a Little bit, mine did too this 
morning because I did not come to town on a loaid of wood. I had 25 
years with Texas A. & M. University and as a county agricultural 
agent I have been working in this field for many years. I have or- 
ganized over 1 ,000 conmiunities in Texas through the years. 

I do come here representing the distii^^uished Governor of our 
State, Governor Clements, who is our firat Republican Governor 
in 100 years. 

This has bipartisan support. He is backing what we are doing here 
today 100 percent. 

In this audience today are also the presidents of some of the live- 
stock organizations from my State and others that will be 
participating. 

I am going to include in my testimony the proceedings of the 
Predator Control Summit that was held in Austin, Tex., just a few 
weeks ago, where the distii^ui^ed Secretary of the Interior, Cecil 
Andrus, was in attendance. He was there and we also asked Jimmy 
Carter, Bob Strauss, and eveiybody else in Washington. We had to 
have bJTn down there to talk to us. 

This report is so good that you could do a doctoral dissertation 
at Harvara on it. There has never been anything pulled together that 
has been any better on the subject at hand. There are hundreds 
of letters in here from managers and others. 

The amazit^ thing about the testimony of the Secretary of the 
Interior — and ne is a very good friend of mine — is that he stated 
that Mr. Connolly, who wiD be here in just a few hours, and who works 
for the Secretary of the Interior, said his research points out that 
1080 is a good thins to use but the Secretary did not Know about his 
research tnat was done in bis own Department. 

I sat in the breakfast room this morning with some of the people 
who are now in this room and I heard from a few dedicated employees 
of the Fish and Wildlife Service about techniques and controls I 



D,g,tze:Jb.GOOg[e 



84 

had never heard of before. One of the employees — and he is in this 
room — will speak on this program later. 

It is DO wonder that the people in the hinterlands think that the 
hureaucracy is full of a lot oi atumblebums. 

He went on, in his testimony, to say that he had directed Mr. Oreen- 
walt to correct the situation. 

I ask you distin^ished members of this committee: How long do 
you think that the people in the hinterlands are going to put up with 
this kind of business? They are beginning to wonder if we can govern 
ourselves, especially in Texas. 

I come this mommg as a commissioner of agriculture. I am an elected 
official. I carried every county in Texas except 17. I also come as the 
commissioner of the third largest food-producing State in this Nation. 

Our shrimp boats are tied up this momii^ in Texas because of high 
fuel costs. We have 6 million acres of land on which grasshoppers are 
up to 80 per square yard. Our hands are tied. We cannot do anything 
about them. 

A great number of years ago I used lOSO as an extension worker and 
we eliminated rats from our State. The headlines of the Dallas Morn- 
ing News on Sunday said that the rats are eating up the poor child- 
ren's toes because we no longer have any effective rat control. 

I want to get into some other points but I must get back to th(» 
testimony here. 

I appreciate the opportunity to speak to you today. The decision to 
bring together the talents and interests of the Departments of Agri- 
culture and Interior to develop sensible, effective animal damage 
control methods is an important one, not only to the State of Texas 
but to the other States suffering losses of livestock to predators. 

I will say to you and to the invisible bureaucracy that writes the 
rules without knowing anything that we have no conflict. The summit 
conference was a meeting of an environmental group, familiar with the 
earth, includit^ the Isaac Walton League and many others. We asked 
them to sit down and talk with us, 

I am an environmentalist. The ranchers of our State are environ- 
mentalists. Without them you do not have any animals. You do not 
have any clear water and blue sky. 

However, we are sick and tired of losing our sources of income. 

To determine accurately the losses of sheep and goats to predators 
in Texas, the Texas Department of Agriculture, in cooperation with 
the Texas Crop and Livestock Reporting Service, performed a survey 
for the year 1978, The survey report, which I submit aa exhibit A, 
showed that $13 million in market value was lost to predators, mainly 
coyotes. Goat and kid losses due to predation amounted to 72 percent 
of the number found dead. 

Over half of all the death losses in sheep was attributed to predators, 
mainly coyotes. Deaths due to predators since 1967 have been increas- 
ing for all breeds. 

On the last page of the report are two charts which tell the story of 
the sheep and goat industiy in Texas. Both show the decline in the 
numbers of sheep and goats, despite the fact that prices and demand 
have risen for both commodities. 

For example, in 1965 there were 4,060,000 Ai^ra goats in Texas. 
Today there are 1,400,000. Sheep numbers decreased from 4,530,000 
in 1965 to 2,400,000 today. 



D,g,tze:Jb.GOOg[e 



There are counties in Texas which once had flourishing sheep and 
goat ranches that now have none. The Interior Department has shown 
no interest in reducing predation in these counties so that herds can 
be started again. 

Cattle were not included in the Texas survey but the loss of even one 
calf today is substantial with present market prices being what they 
are. The Department of the Interior cited a loss range of 0.6 percent to 
1.1 percent of calves to predators in a 1977 study covering the Great 
Plains and Western States. 

These figures are presented in the Final Environmental Impact 
Statement of the anunal damage control program, issued in June 
1979. If those percentages were applied to Texas today the value of lost 
income w'ould be from $15 to $28 million. 

Let me tell you how a coyote kills a little calf. He eats his kidney out. 
He tears his hind quarter off. He cuts his throat. It is a suffering, 
maiming, terrible thmg to see this happen. 

Predation also affects range man^ement practices for cattlemen. 
Ooats are used to clear brush in native rangelimd where cattle graze 
and have proved to be excellent at their job. 

We have thousands and thousands of acres which are now being 
inundated by the mesquite tree. It is crowding out ourgrass and there 
is rule after rule stating we may not use 2,4,5-Tor2,4-D.The goat has 
been very effective in helpii^ us to control brush and I am sure we 
would all prefer a natural weed killer whenever possible. When preda- 
tors kill off the goats the rancher must then turn to herbicide treat- 
ments which add to his production costs. 

For the past decade hvestock raisers have lost one control method 
after another through decisions made by persons far removed from 
agriculture. In some cases it appears to ranchers that bias against any 
means of animal damage control has blurred the vital scientific 
objectivity necessary for Government to make decisions that affect 
millions of dollars in income. 

The Department of the Interior is charged with the very important 
responsibility of the protection of wildlife m our Nation ana it is imder- 
stiuidable that personnel may be overzealous in their drive to preserve 
tins important segment of our environment. 

Ranchers have felt that research directed by the Interior Depart- 
ment has been unduly influenced by anti-animal damage control 
proponents. The hallmark of scientific excellence is truth and objec- 
tivity in reporting research and the public must have a means of 
achieving an unprejudiced search for the best methods to solve 
problems. 

Let me remind you that for more than a quarter of a century I was 
the extension leader of the land grant university in Texas, along 
with doing research and teaching. 

The Agriculture Department is concerned with progress in domestic 
livestock production and is aware of the needs of ranchers. We applaud 
the efforts of this committee to create a shared responsibihty for 
animal damage control. 

The inclusion of compound 1080 as a subject for continued research 
is most important to Texas ranchers. In Texas we are seeking an 
experimental use permit for the chemical in the toxic collar, for it 
shows real promise. 



D,g,tze:Jb.GOOg[e 



86 

Let me be stire that people know what we are talking about. We are 
talking about putting a little plastic bag around the sheep's neck such 
that when the coyote comes out to kill him, it kills the c<^rote. That is 
what we are talkmg about. 

Freliminaiy research at the Denver Wildlife Research Center, an 
interior operation, indicated that there was no evidence of secondai^ 
poisonii^ hazards from the chemical. I hope jrou will protect him if 
retributive measures are taken (gainst the scientist who made these 



The hazard to nontai^et species was part of the rationale given by 
the Environmental Protection Agency for ite suspension. Further 
research can prove or disprove its danger to nontaiget species. 

Another advantage of using compound 1080 in the faozic collar is 
that the chemical kuls only the offending animal not all of a species. 
There is absolutely no threats of eradicating an entire species. We now 
have coyotes, I learned this morning, all the way into Mississippi. 
We have no Mortage of coyotes. 

Details of research on compound 1080 are covered in exhibit B. 
Proceedings of the Predator Control Summit, which was sponsored, by 
the Texas Department of Agriculture in January 1980. Our depart- 
ment drew together representatives from environmental groups, the 
livestock industry, and Government agencies, including the dis- 
tii^uished Cecil D. Andrus, Secretary of the Interior. 

ui my opinion, the report of the proceedings is one of the most 
complete documents of the problems of animal damage control ever 
published. 

Policies of the environmental groups, Government agencies, jmd 
current conditions are included in the publication. I encouri^e com- 
mittee members to read the testimony, especially the letters from 
ranchers who are suffering as a result of Government policies. 

The Interior Department's policy statement of November 1979 
stressed that the emphasis of future research would be placed on 
nonlethal devices and improved animal husbandry practices. The 
livestock industry would welcome research on either of these methods 
if they held promise of success in the near future. However, so far 
none tested in field studies have reduced predation. 

Various proposed fences have impeded deer migration and are 
costly to instil and maintain. In addition, most have simply not 
repelled the coyote. Sheep herders have also been proptwed an 
answer but they are truly a nearly extinct breed. Penning herds at 
night has resulted in the coyotes' digging under fences anaBwitchii^; 
their killing to daylight hours. 

We feel that major immediate emphasis should be placed on methods 
that could be put into practice now or without undue delay. Any 
delay is a costly one. Each day that passes means that mora sheep, 
goats, and calves are being killed. 

The longer we delay in finding an answer, the more ranchers will 
go out of the sheep and goat business, and the lomer we delay, ihe 
miore predators will multiply to prey on the Nation's livestock. 

Five years spent on noise, scent, and taste aversion techniques will 
be fruitless ones for ranchers. We believe that personnel from the 
Department of Agriculture will understand and will act on the need 
to push for research on practical solutions that can be implemented 
now. 



D,g,tze:Jb.GOOg[e 



87 

The delay is not only costly but is also frustrating. Today many 
citizens feel that they have lost control over their own Government. 
It is not Dews to anyone in this room that Americans are growing 
more hostile toward unelected ^eacy personnel who create and 
enforce regulations with little re^rd for their economic impact. 

Some groups wish to wave aside anv mention of dollars and cents 
when dealing with the environment but the farmers and ranchers 
affected cannot afford to do so. The economic value of wool and mohair 
in Texas in 1979 was $65.9 million. Mohair prices are the highest they 
have ever been in history. 

We met with the South African wool growers. We just completed 
a mission to South Korea and Japan. We are working all over the world 
and we cannot let this business go down the drain because we can- 
not protect goats on our own farms and ranches. 

When a ewe is killed, not only her market value is lost but the income 
from future lambs or kids is lost and the income from wool or mohair 
cli^ .vanishes. 

That income is not all that is vanishii^ from the American agri- 
cultural scene. I believe that this country is facing a food crisis. 

When the Commissioner of Agriculture of the third lai^est pro- 
ducing State in the Nation voices that type of concern, I beheve that 
lawmakers must and will listen. In an era of plentiful supphes of milk, 
wool, mutton, cotton, Eind other farm producte this concern falls on 
deaf ears, but with the continual loss of farm and ranch families and 
with expandi^ domestic and world populations, the handwriting is 
on the wall. We must protect those engaged in feedii^ and clothing 
our people. 

Those in leadership who do not use commonsense in dehberating 
matters affecting food and fiber production will wring their hands in 
despair when it is too late. If we lose certain segments of agriculture, 
such as the sheep and goat industry, it will take years to reestablish 
herds when we need them. 

Many in husbandry beUeve that it will be impossible to revive a 
dead industiy. We must not play Russian roulette with the lifeblood 
of this Nation, the agricultural industry which gives the United 
States a trump card in mtemational negotiations. 

This is what we are talking about today — not coyotes or tambs — 
it is food and hber for this Nation. 

' So far, the arguments from ranchers have apparently not reached 
decisionmakers or have been ignored by some in Washington who 
seem to have developed tunnel vision where predators are concerned. 
We beheve that making the Department of Agriculture an equal 
partner in animal damage control pn^rams could provide a balanced 
dimension and will, we nope, give ranchers a voice in pn^^rams their 
tax dollars support. 

Listen to me. Todtn^ our shrimp boats in Texas are tied up, mostly 
because poUcies are bringing in the Vietnamese. They are building 
boats by the hundreds down there. 

Our sheep and goat industry is being decimated by coyotes. I have 
just come bock from Mexico. I sat with the fellow who sits at the 
right hand of FortiUo. They have 70 million people in Mexico and 
15 million of them hve in Mexico City. Fifty nercent of the nomiintinn 



D,g,tze:Jb.GOOg[e 



in Mexico is over 50 years old. They do not have any food. They 
caimot produce it. 

Id South Korea there are 40 millioa people. We just left a delegation 
yesterday in AmahUo, Tex., who said that 70 percent of their country 
IS mountainous. 

Last week we signed contracts for 325,000 bales of Texas cotton 
with Taiwan, Every acre of land in Russia is as for north as New 
York State. 

I am the commissioner of agriculture of the third largest agricul- 
tural producing State in the United States and we are down to 159,000 
fanners. In the hundreds and hundreds of apartments I see in this 
beautiful citjy, in New York and Philadelphia it is brooder house 
living, I read the question: Who is going to produce the food? 

I plead with you, gentleman. We did not ny all the way across the 
United States — I cannot tell you the urgency. I have tried to incor- 
porate into some of my testimony that food is our trump card. Friends 
are going to look to us and we must depend on long-range policy 
concerning agricultural sales. 

We cannot sit idly by and see one of the gratest industries in our 
State, in Montana, Nebraska, North Dakota, and South Dakota, and 
many other States go down the drain because we cannot brii:^ the 
scientific minds and expertise of certain people into a workable 
program. 

Congressman de la Garza, I commend you for your legislation. We 
ore going to do everything we can with every means we have — from 
the President of the United States down — to enact some way to pro- 
tect our environment and the wonderful people who love it and yet 
continue to produce the food and fiber in this Nation that we needf. 
Thank you very much. 

Mr. DE LA Garza. Thank you very much. Commissioner. 
Without objection, the material you supplied will be included in the 
hearing record at this point. 

(Proceedings of the Predator Control Summit and 1979 Texas Sheep 
and Goat Death Losses and Marketit^ Practices are held in the sub- 
committee file.] 

Mr. DE LA Garza. Mr. Wampler? 
Mr. Wampler. Thank you, Mr. Chairman. 

Commissioner Brown, I want to thank you for your statement. It 
obviously shows a great depth of concern and strong feeling on a matter 
about which you are obviously very knowledgeable. 

Earlier this morning we heard other witnesses comment about the 
biological control of weeds and brush. Let me just relate an experience 
that I had earlier this year. I had the pleasure to be at Baylor Univer- 
sity for the dedication of the legislative library named in honor of our 
former distinguished colleague and chairman of this conmuttee, Mr. 
Poi^e. 

While there, we spent the night in Temple, Tex., and viated the 
research station at Temple that, I think, is carried on jointly by 
USDA and Texas A. & M., at which they are trying to find ways to 
control certain brush, mesquite and others, that would not only nave 
the effect of controlling these weeds but also of freeii^ up a siffnif- 
icant amount of moisture that is now being oonsimied by tbese 
noxious weeds and other plants. 



D,g,tze:Jb.GOOg[e 



If I understand the agricultural practices iu Texas, use of goat herds 
does have a positive impact on controlling weeds that otherwise 
nature does not control. la that correct? 

Mr. Brown. That is absolutely correct, Congressman. We are u^ng 
the scrub brush and weeds to produce a salable product. 

Mr. Wamflbb. It seems to me that this is an effective and environ- 
mentally acceptable way to balance nature and to address our concern 
about tJie encroachment of needless weeds which consume thousands 
of acres of rangelands that could be put to more productive uses as n ell 
as to conserve water. If I understand the topography and geology of 
Texas, a good deal of it is, at least, semiahd and water is scarce, partic- 
ularly at certain times of the year. Is that correct? 

Mr. Bbown. It is absolutely correct, sir. 

Mr. Wampleh. There is one other thmg that you mentioned in your 
very comprehensive statement. We heard suggested today by others 
that fencmg would be one effective way to control predators and you 
commenteuon that. Do I understand you correctly that it is your 
feeling that fencing is not an effective way, even if you were to corral 
livestock? 

Mr. Bbown. Absolutely, sir. It is an asinine su^estion. It will not 
work. It is not economically sound. 

You can go out to Sears Roebuck and get a cyclone fence about IS 
feet high, dig a ditch, and pour a concrete slab 4 feet deep. Then he 
could not dig under it and he could not jump over it, but who has the 
money to do that? We have to use economics. 

Most of our sheep and goats are produced out in the wide open 
spaces of Texas. The sheepman has penned his sheep for years. It is 
a common practice using corrals but they have not found many fences 
that the coyote cannot get over or under. 

Mr. Wampler. I gather also, from your testimony, that you have 
the feeling that there is a large pot«nti^ for export of goat and lamb 
to — I think you principally mentioned Mexico but there are other 
potential markets that coiud be developed if we could be a reliable 
supplier. Is that correct? 

Mr. Brown. If I had refrigerated ships I could. In America we do 
not have those refrigerated snips. We could ship, in the next month, 
every sheep and goat we have m the State of Texas. They would buy 
them. The Saudi Arabians would buy them. They have the money. 
They are upgrading their diets. 

I mentioned 53,000 head, Coi^ressman Wampler. I administer 6 
livestock export pens; 120,000 head of cattle have gone all over the 
world through my pens. That is getting our dollars back. 

We export over $2 billion worth of agricultural products from Texas 
each year out of, I beheve, the total $38 bilhon of American exports. 

The stock that we ship to Mexico are old ewes. When I became 
conmiissioner of agriculture, we had no market for these old ewes. 
They grew old, died on the ranches, and the buzzards ate them. 
We lound that in Mexico they had a market for the older ewes. We 
were able to market the pelts and then they use the older meat to 
put in different foods that they use down there. 

Fifi^-three thousand of these have gone through our export facili- 
ties. The ranchers have been getting checks for $5,000, $6,000, and 
$15,000 for something for which he had no market. 



D,g,tze:Jb.GOOg[e 



00 

The older ewes are very easy for the coyote to kill. That makes for 
a lost market. 

One of the causes of inflation in our country is that we are sending 
dollars out for oil. Agriculture is about the only thing we have tefb 
to get our dollars back. 

We have a tremendous market. I just came back from Europe. 
We could ship all we can get of the Texas Ruby Red grapefruit, 
from the Congressman's district, to Germany and France. They know 
about Texas Ruby Red grapefruit. 

Concerning our cotton, we made 5.7 million bales of cotton in 
Texas this year. It is the lai^est crop we have ever OLade. We are |^ing 
to export most of it. We sent 325,000 bales last week to Taiwan. 
Orders are coming in eveiy day. 

I left a group from Sweden yesterday. They are here to buy. That 
is the name of the game, Congressman: Sales. 

But listen, if the grasshoppers take over— there are 6 million 
acres in Texas now that have 80 grasshoppers per square yard. It 
goes into New Mexico, Colorado, and up through the Dakotas. If the 
Friends of the Earth prevent us from spraying, they will obliterate 
eveiy bit of our crops. Eighty grasshoppers per square yard will eat 
the fence posts. They will eat the barbed wire if you are not careful. 
It is dai^erous when you have eight. We have to control grasshoppers. 

We cannot let our grass go. Without grass we cannot produce 
cattle. Then the person trying to buy a steak in New York suffers. 
All these things work together. 

We are now, in Texas, down to 30 people that produce all the e^s 
in our State. Some of them have 1.5 million hens. One of theae days 
they will decide that ^;s are to be $5 a dozen. 

Consumers had better be listening to what I am saying. We must 
protect agriculture. 

We lost 2,000 farmers in our State last year that went out of busi- 
ness, partW due to high interest rates. My son is the vice president of 
a bank. He made cattle loans last week at 21 percent interest. You 
show me anyone. Congressman, who can make any money with 21 
percent cattle loans. 

Yesterday, in Amarillo, Tex., I sat with cattle-feeding, hard- 
handed men — you shake hands wiUi them and it is like putting your 
hand in barbed wire— that feed out 10,000, 50,000, or 60,000 head of 
cattle. They were losing $300 a head. How long do you think you will 
have steaks in Washington if this goes on? 

Although now I am getting off the subject. We are not talking about 
coyotes and lambs. We are talking about a food and fiber supply tor 
this Nation. That is what we are talking about. 

We are seeing it dwindle all the time. 

Mr. Wampleb. I have one final question, Mr. Chairman. 

Mr. Brown, I know that you are an individual who has had a loiu; 
and distii^uished career and experience in the mission of our lancf 
grant collies and universities, especially as it applies to research 
and teaching in extension. 

You heard the testimony earher this morning. I was appalled when 
it was revealed that the Secretary of the Interior decided not to let the 
scientific community make some basic determinations on the de- 
sirability of using certain chemical compounds as a method to try to 
control predatoiB. 



D,g,tze:Jb.GOOg[e 



91 

Do you agree with me that in fact we ought to press forward to get 
more scientific research to find viable alternatives, rather than these 
decisions being made on political, enviromnratal, socifd, or whatever 
other grounds there might be? 

Mr. Beown. Coi^ressman, for more than a quarter of a century I 
have been involved in research. The man that looks into the test tube 
and the microscope is the hope of this Nation. 

Everything that we can possibly do to control predators, as the 
distinguished gentleman testified, is good. We need U> accelerate that. 
We need to pen all of the other types, but we must also use thii^ that 
the Department of the Interior m. its own research say are not too 
dangerous. 

We have had vast experience with 1080 in our State. Out on those 
targe ranches we will not get the secondary killing, in my opinion. 
Research also points that out. 

Right now the palm trees on the Rio Orande River are dying from 
disease. We have a terrible hog disease from Cuba that is commg in. 
We have all of these things — animal health, environmental control, 
water utilization — to which we have to find answers because in the 
next 20 years we will double the population of the world. That is a 
known fact. And who is going to feed them? Who is going to feed 
them? 

If we let the rangelands grow up with brush in Texas, we let our 
sheep and goat industry go down, once we lost it we woi^d probably 
never get it back or it would take years. 



If you do not listen to what I am saying here today, you will wring 
your nands in about 8 years and say, "My gosh, whv didn't we listen 
uid guard the food supply of this Nation? " 



Let me add this. We are importing 18 percent of our fruit and v^e- 
tables from Mexico. I administer all the inspection services, not only 
for my State but for Mexico aa well. If we did not import the fruit 
and vegetables from Mexico we would not have them. 

I am a great believer in the idea that we ought to grow them, but 
who is going to grow them? We have gotten out of business. 

I used to be county agent in the county where the extension service 
was bom. I had 43 grade A dairies. Now there is not a grade A dairy 
left in that county. 

Do vou see the point I am making? I plead with you here, as we 
talk about the sheep and goat industry, not to let them go the same 
w&y. 

Mohair people are making money. There is a great world demand 
for sheep and goats. Let us help our ranchers protect them. Let us 
find a better way but right now let us use the tools that we have. 

My department is responsible for administering the M-44 devices 
and all that. We have had very little problems. 

Mr. Wamplbr. Commissioner Brown, I thank you very much. Let 
me assure you that I am going to read the proceedings of the predator 
control summit. I have nad a chance to hurriedly thumb throu^ 
it during your presentation, not that I was not listening to you. I 
was listening to you and thumbing at the same time. As you say, I 
Uiink this oi^ht to be required reading, not only by eveiy member 
of this committee but by anyone who has an interest in this subject. 

I am talking about those on all sides of the controversy. It appears 
to me to be a document that puts in clear focus what our alternatives 



D,g,tze:Jb.GOOg[e 



92 

are, what our choices are, ami what the effects of those choices are 
going to be on maintaining viable agricultural capabilities in this 
country. I think you have summarized it so well this morning. 

Mr. Brown. I want to say to you, sir, as the ranking Republican 
member on this great committee, that we appreciate the leadership 
that is beii^ exhibited here. 

I apologize a little bit for my enthusiasm. I am trying to have you 
understand how really important it is, and in Texas we believe in 
winnim. We do not believe in holding actions or fighting a losing cause. 

We do not believe our country is in bad shape. We do not believe 
our boys and girls are in bad shape. We think we have the greatest 
country in the world. We fought two wars on two fronts. 

Our gross national product today is greater than Russia's or anyone 
else's. Let us get with it with commonsense and solve the problema 
together and I think our country will be all right. 

Thank you very much. 

Mr. DE LA Garza. Commissioner, let me ask one question. You 
have applied or are applying for an experimental use permit on the 
toxic collar. Is that correct? 

Mr. Bhown Yes, sir. The research of Mr. Connolly in the Interior 
Department is carried out on Mr. Howard's ranch. Mr. Howard will 
be testifying tomorrow. 

If we can use that we will stop the killer coyotes and there will stUl 
be plenty of coyotes left. 

Mr. DE LA Gakza. Thank you very much. 

Mr. Wampler. Let me just say this. You were somewhat apologetic 
for your lack of brevity, I have never known a Texan to be a person of 
a few words. [Laughter.] 

Seriously, in Virginia we pride ourselves on the fact that so many 
Texans came from Virginia. It is a matter of historical note that 
Stephen Austin was bom in my congressional district and Sam Houston 
was bom not too far away in the valley of Virginia, Our former dis- 
tinguished chaiiman of this committee, Mr. Poage's grandfather was 
bom in Virginia. Bob always said he had the good judgment to go to 
Texas at a young age. 

We have a close feeling for people in Texas and we know 

Mr. Bhown. Bob Poage is a dear friend of mine of more than 30 
years. I was at Baylor with you. I remember meetii^ you, sir. The 
only thing I can say is that I am briefer than Bob Poa^e, [Laughter.] 

Mr, DE LA Gahza, Thank you very much. I would hke to mention 
that I had a grandmother named Vii^inia. [Laughter.] 

Mr. Wamflek. We will take judicial notice of that. 

Mr. DE LA Garza. The committee will stand in recess until 2 p.m. 

(Whereupon, the committee stood in recess.] 

AFTERNOON SESSION 

Mr. DE LA Garza. The subcommittee will be in order. 

The first witness is Mr. David Flitner, president of the Wyoming 
Farm Bureau. We welcome you and will be happy to hear from you at 
this time. Without objection, your full statement will appear in the 
record. If you would like to, you may summarize it. 



D,g,tze:Jb.GOOg[e 



STATEUENT OF SATID FLITirEIl, PBESIDEHT, WTOMDVa FASK 
BUSEAU, KEFKESENTINO AHEEICAN FABM BUKEAU FEBERATIOZT 

Mr. Flitnbb. Thank you very much, Mr. Chairman. 

If that is agreeable, I will proceed on that basis. 

As my statement indicates, my name is Dave Flitner. I am a full- 
time farmer and rancher in Wyoming and I am also president of the 
Wyoming Farm Bureau. 

I am here this afternoon representing the American Farm Bureau 
Board of Directors. I think I was prooably chosen for this respon- 
sibility because of the fact that our own operation in Wyoming has 
been impacted by predators to the point that it has caused ub in the 
past year to phase completely out oi the business. 

Because of our extreme mterest in this particular issue, as in- 
dividuals and as a large general agricultural association, I want first 
to state, Mr. Chairman, that I compliment you for the legislation we 
are looking at and analyzing today. We feel that this is the type of 
leadership that we in agriculture have been waiting for. 

I would also like to reci^nize, even though he is not here at the 
moment, the efforts of Congressman Wampler. I would also like to 
express my appreciation to Congressman Marlenee of Montana who 
is not a member of this committee but was here this momii^. We 
certainly appreciate his interest in this subject. 

As I said, I am a full-time farmer and rancher and, I guess you 
might say, part-time president of the Wyoming Farm Bureau. In 
1904 our family came from the New England area and established a 
ranch in northwestern Wyoming. At that time we were solely a cattle 
operation. 

In about 1930 we diversified and also went into sheep. We did so 
for several reasons, one of which was to utilize the type of grass 
habitat that is evident In that part of the State more efficiently. As 
I think was brought out here this morning, the sheep use the rather 
unfortunate tailings, you might say, of the western ranges such as 
dandelions and other weeds. That makes it possible for the coarser 
grasses to thrive in greater abundance, makit^ them available for 
other domestic, heavier footed livestock and wildlife. 

We maintained a ranch on this basis, with sheep and cattle, from 
1935 until about 1975 when we started to phase out of the sheep 
business as the result of extreme predation. I will not go into that 
except to say that we ran 2 to 2K bands at one time which amounted 
to something over 1,000 head of ewes in each band. 

We could see that the predatory animal problem was such that we 
could not justify two bands of sheep and, as I said, we phased down in 
1975. 

In 1979 we tried one last attempt to survive in this business and we 
failed. We failed because we took a 500-head loss in our operation in 
lambs alone, not counting ewes, from predators. 

I am here this afternoon as somewhat of a living testimonial to the 
fact that we, in the western port of America — and I have talked to 
many people around the United States with r^ard to this predator 

Pressure and find it is everywhere. They are having problems of hogs 
eing killed in Iowa. They are having problems in the Southeast m 
places like Louisiana. We are having tremendous problems in the West. 



db.Google 



94 

In Mimtana cattle are being killed — calvee, sheep, and, of couise, 
wildlife exe also being impacted. 

I guess I am before you, Mr. Chainnon, and your committee in a 
Bomewhat frustrated attitude. I think I reflect the kind of frustration, 
if not nearly despair, that is experienced by people who are trying to 
produce food ana fiber in our society. 

If it is, indeed, in the national interest to elevato predators to a 
status above those of us who produce food in tbe United States of 
America, then I think it should be so stated and we should be told 
forthwith that we, who try to produce food, are a. secondary 
commodity. 

We have seen the Animal Damage Control Act of 1931 , 
which revised the lethal potentials for eliminating coyotes, changed by 
bureaucratic repeal. Therefore, I feel I am before tnis subcommittee 
unnecessarily because I do not think that was the intent of Congress. 

I gather, from what I have heard here this morning, that this is 
certainly not your philosophy, Mr. Chairman. Nevertheless, it has 
impacted our industry to the point where some of us have been driven 
out of the business. 

Maybe people or society in general can say: Well, what difference 
does it make if we do not have the opportunity to raise sheep and 
goats and if it even becomes more difficult to raise cattle or wildlife in 
the United States? 

In answer, I say that I do not think it is in the national interest to 
have a society based on nonproductivity. I think that it is time tJiat 
society in general decided on some prionties. 

I, mysefl, have never killed a coyote in my life, but I have been 
responsible for alerting the professionals who are chained with that 
responsibility so that they could try to reduce the coyote population 
so that we could survive. 

The members of this committee who were here this morning, I 
beUeve, could have sent their children, not knowing how many they 
have, to nearly any college in the United States on the amounts of the 
losses we have incurred m one valley in northern Wyoming over the 
past 10 years. I think that it is time that society in general come to 
our assistance and try to give us some kind of relief with respect to 
this matter. I believe it is time to establish some priorities so tnat we 
are not disenfranchised for the fact that we happen to be the producers 
of red meat in America. 

Mr. Chairman, you have my full statement. This summarizes some 
of my concerns and I would be happy to try to answer any questions 
you may have. 

Mr. DE LA Gakza. Thank you very much, Mr. Flitner, 

Your statement will be included in the record at this point. 

[Statement of the American Farm Bureau Federation follows:] 



D,g,tze:Jb.GOOg[e 



STATEHEtn OF THE IkHEKICAN FARM BUHEAU FEDERATION 

BEFORE THE SUBCOHHITTEE ON 

DEPABTHEHT INVESTIGATIONS, OVERSIGHT AND RESEARCH 

OF THE aOUSE COMMITTEE ON AGHICIILTURE 

NITB REGARD TO H.R. 6725, ANIMAL DAMAGE CONTROL ACT OF 1980 



Apcil 16, 19SD 



The Anerlcan Farm Buieau Federation Is a general Earn organtia^ 
tlon ulth over 3 nllllon menber fantUies In 49 atateB and Puerto Slco. 
Faim Bureau members are engaged In the production of viEtually every 
couterclal agricultural product marketed In the united States, 
Including the production of cattle, sheep and goats. 

He were ccmpletely dismayed uhen the Secretary of the Interior 
announced on November 9, 1979, a revised federal policy on the control 
of damage to livestock caused by predatory animals, primarily coyotes. 
The Secretary chose to Ignore fact and reason In favor of idealistic 
passion hy ellsinating lethal control measures. The result Is the 
loss of any real protection against predators, especially for the 
livestock producer In the Nest whose animals graze the remote areas 
of the public lands. 

The Animal Damage Control Act of 1931 directs the Secretary Of 
the Interior to control predators by both lethal and nonletbal methods 
for the protection of livestock. Congress has, over the years, 
expressed Its ongoing concern for an effective federal animal damage 
control pcogciu. Foe fiscal year 1980, Congress budgeted over $17 
million for the progcaoi. 

c control policy effectively repeals the 1931 
a new predator protection law. Instead of 
controlling predators, the Departnent of the Interior proposes that 
livestock be controlled. This Is readily apparent In the President's 
1977 Environmental Message to Congress, wherein he said, "Because we 
now realize the importance of the role that predators play In various 
ecosystems, our goal should not be to destroy them but to reduce the 
occasion for their conflict with livestock," 

In other words, ve are going t 
tors. We are going to remove ]* 
predatory animals roan. 

We see no other interpretation. Coyotes are not respectful of 
Intanglhle boundary lines — nor many tangible boundaries for that 
matter — so we can't set aside a predator reservation for them and 
^, i__ ,, ^ " ' ■ ■ er can you herd coyotes to keep them 

In the case of coyotes, nonlethal control measures are about as 
affective as serving cease and desist orders. Thus, under the pro- 
posed policy, the only way to prevent the coyotes predation om live- 
stock is to not have any livestock. 



D,g,tze:Jb.GOOg[e 



Wien livestock neans lenovlng livestock fzim the public lands. If one 
CKinBlders the overall direction of public land managenent by tfae 
federal goveinment today — to exclude any ubs of public lands In favor 
of wildernesB preservation — getting livestock off the public lands Bay 
very Hell be a najoi objective of the cevlsed predator control 
program. 

Look at the specific policy goals enunerated in the revised 
policy statement. In policy goal number 1, preventive control 

measures would be United to specific situations where unacceptsbly 
high levels of losses have been documented during the previous 12 

This policy goal statement assumes that certain levels of live- 
stock loES are acceptable, when in fact no loaa Is acceptable. It 
alEo implies that,^ for at least the first 12 months, no preventive 
contFolB would be available to the livestock producer from the federal 
animal damage control program. 

Policy goal number 2 says that If control measures are ever d*ened 
appFopriate, nonlethal methods only should be employed and then only 
against offending animals. In other words, first we get a conviction 
and then we harass the culprit. 

Goal number 3 specifies that conflicts between predators and live- 
stock should be solved through husbandry techniques which decrease ex- 
posure of livestock to predators. This means the removal of livestock 
from the realm of the predator, especially public lands. 

Goal number i would extend the availa 
services. There would be nothing to extend other t^ 
and someone upon whom the livestock producer could v 



need. Program tesourcea have always been concentrated wherei, and whenw 
needed. ^ '■ 

Goal number 6 redirects and refocuses research to preventing pre- 
dator damage. Once again, the federal government is proposing studies 
rather than action. Years of study have already proven that nonlethal 
control measures are ineffective and the obvious direction of the stu- 
dies is to elevate predators to the position of the animals protected 
by the animal damage control program. 

The statement ot revised policy then goes on to eliminate tbe^ 
predator control practices of denning, aerial shooting, traps and Com- 
pound 1080. m the light of the Environmental Impact statement pre- 
pared on the animal damage control program, these measures are the 
only effective measures ava labia but are objectionable to a certain 
element of our society who view predators, especially coyotes, as fun- 
loving Walt I>isney characters. 

If these and other lethal control measures were to be removed 
predators, especially coyotes, would abound. Livestock production, es- 
pecially sheep, would dramatically decrease. It has already. In 19S0, 
there were some 30 million head of sheep in the United States. Today, 
there are only about 12-5 million. One of the major cauaes for the re- 
duction is the federal government's progressive limitation oo letbal pred- 
ator control measures. 

Mr. Chairman, Farm Bureau finds the revised federal predator 
control policy contrary to existing laws and we support current 
legislative efforts that will restore lethal controls to the fed- 
eral animal damage control program as soon as possible. 



D,B,i..ab,Google 



97 

Mr. DE LA Garza. I do have a couple of questions. 

First, let me say how sad it is to hear stories like yours. They have 
been repeated throughout the area where the sheep and goat industry 
used to be. We, here, are trying to do something tnat wiS help within 
the scope of the concerns of other people. 

Was your production replaced by someone, to your knowledge, or 
when you went out of the business was that production simply lost? 

Mr. Flitnbb. In a sense, Mr. Chairman, our production is being 
replaced. We are transferring our production from sheep to cattle. 

We had cooperated with specialists from Australia and the most 
eminent sheep producers in America to try to evolve the finest animal 
available anywhere in our part of the United States. We did this for 
35 years. So, it was with a great deal of anxiety that we finally threw in 
the towel and decided to abandon it when it became so evident that 
we could not survive. Last year, in lambs alone, we had a $30,000 
loss to coyotes. 

Mr. Chairman, I know that there are people in this room, all across 
America, and in my own hometown who do not believe this, but the 
sheep industry in my locale, in my State, and in many other areas is 
evidence in itself. It is being eliminated. It is certainly being eliminated 
in my area where there are only two operations left, and there used 
to be 10 or 15 years ago. 

Mr. DE LA Garza. Is it true that the production from those opera- 
tions that have fallen by the wayside is just lost? 

Mr. Flitneb. Yes, sir. That production of sheep is lost. 

Also, the employment in our sheep operation, although we were not 
a large sheep operation with those two bands, but we did have a 
round-the-clock lambing operation and employed about seven full-time 
people for 2)^ to 3 months, is lost. The beneficial monetary impact on 
the local community and on employment opportunities are lost, as 
well as the resource. 

The most damaging loss, in my view, is the fact that those western 
ranges lend themselves to the raising of sheep. From a conservation 
standpoint it is beneficial to the range to have both sheep and cattle 
browsmg because of the weeds that they eliminate. 

When we finally made the decision to remove ourselves from the 
sheep business we thought that we would see a decline in the productive 
capability of the land because of the fact that we would not be 
eliininatii^ some of the undesirable grasses, such as dandelions and 
other weeds. 

Mr. DE LA Garza. Did you have any other predators besides 
coyotes? 

Mr. Flitner. Yes, I did, Mr, Chairman. I hesitate to mention 
this, but we are impacted by nearly every predator in our region. 
We have sustained losses from bear. We have sustained losses from 
mountain lions. We have sustained losses from golden eagles. 

Of the 500 head that we lost last year, we lost, conservatively, 
300 head of baby lambs to golden eagles. I would not have believed this 
before, Mr. Chairman, had I not seen it with my own eyes. 

We lost 300 head of baby lambs to golden eagles wmle they were 
lambing on the range within 15 miles of our ranch headquarters. We 
moved that herd and docked and branded the lambs. We took them 



D,g,tze:Jb.GOOg[e 



98 

to our private pastures on the Bi'; Horn Mountains and we lost 200 
head, so in total we lost 500 head to predators this past year. That 
does not account for any adult ewes which were not, as I said, in- 
cluded in the tally. 

Mr. DE LA Garza. What is the size of the ran^e where you had 
your sheep? 

Mr. Flitnek. In the area where the eagles were aproblem, Mr. 
Chairman, our range is divided into three pastures. That particular 
pasture is 13 square miles. 

As you well know, Mr. Chairman, goklen eagles are a national 
symbol. They are on the endangered species lists. 

When we saw what was happening, my father, who is 79 years old, 
rode out with me and we witnessed in a half a mile 12 dead baby 
lambs. When we gathered the sheep, in one day we saw 43 baby 
lambs who had been killed by golden eagles. 

My father said — he had been raisecT in that country — "That is 
enough. We cannot afford to be the sacrificial lambs for society any 
longer." He said, "I think it is time that we sacrifice our legacy of 
production to society. God help them!" 

Mr. DB LA Garza, Then in that area, basically for the reasons which 
you have so well described, the sheep and goat raiser is the endangered 
species rather than other wise. Is that so? 

Mr. Flitnbr. That is correct, Mr, Chairman, and it is very un- 
fortunate for America that we have elevated any type of predator 
to this kind of status in America. 

What has built this great country is the ability of people to produce. 
There is nearly despair in ray part of the country with respect to the 
fact that on every side government is pressing down on people like 
me and others who are trying desperately to produce food and fiber 
and other things for America. 

For some bureaucratic or other reason, constraints by government 
are frustrating us at every turn. It is destroying America, Mr. Chair- 
man. You know it as well as I do. 

Mr. DB LA Garza. Of course, on that 13 square miles you would 
have to build a cage to keep the eagles out, but were you to fence with 
a predator-free fence, if there is such a thing, what would be the cost? 

Mr. Flitneh. Mr. Chairman, we considered all avenues in an effort 
to try to salvage this genetic legacy of which we were bo very proud. 
The cost that would be associated with the type of fences, iacluding 
electrical fences — we have friends in AustraUa that use electrictd 
fences — would be so horrendous. 

As the commissioner from Texas mentioned this morning, the 
coyotes still have the ability to dig underneath the fences. It is not 
even within the realm of economic feasibility to consider it in any de- 
tail because the cost would be so prohibitive. 

In the one IS-square-mile pasture there is approximately 8 miles of 
fence and in the total perimeter there are prooabty 20 or 30 miles. 
This sounds like a tremendous operation, Mr. Chairman, but it is a 
great deal like much of Texas and much of our western country. It 
takes 20 acres per cow per month. 

If we were not utilizing this resource of land, Mr. Chairman, it 
would essentially be laid wast« from a grass standpoint. Deer are not 
there. Elk are at higher elevations. Those of us that happened to use 



D,g,tze:Jb.GOOg[e 



99 

this ^e of country have fenced it in in order to try to get something 
beneficial out of that land. 

When you consider the economics of any type of fencing, because of 
the vast number of acres required per animal unit, it is not feasible. 

Mr. DE LA Gabza. In the area where you had the sheep, can cattle 
be brought in? 

Mr. Flitnbr. We have brought cattle in, sir. We are phasing cattle 
into the operation but much of it is salt sage country that lends itself 
to sheep. There is not the opportunity to capture very much water. 
The time that sheep utilized the area was in the winter time when 
there was snow there and they would do very little damage to the 
range under proper management. 

We flew the country this past week to check to see if there was 
adequate water to use in the pasture which would allow us to range 
rotate some of the other pastures. We found that there was not ade- 
quate water this year to use that 13 square miles. 

I guess you might say, depending upon the year we are beii^ denied 
the opportunity to use part of a resource that we have previously 
used on a regular basis with sheep. 

Mr. DE LA Garza. You have stated that otherwise there would be no 
utilization at all in that area at those elevations, 

Mr. Flitner. It will depend upon the rain. If there is not enough 
rain to fill the reservoirs we will not be able to use them. This year, it 
looks like we will not be able to use that. If we do use it, it will result 
from the fact that we have rain from this point onward, which we are 
not very likely to have. 

Normally those reservoirs are filled by snow and we did not have 
any amount of snow in this part of Wyoming this past year. 

Mr. DE LA Garza. Thank you, sir. 

Mr. Wampler? 

Mr. Wampler. I have a brief question, Mr. Chairman. 

Thank you, Mr. Flitner. I am sorry I was delayed in arriving at the 
committee meeting this afternoon. 

Let me ask you one question. There appears to be a good deal of 
controversy over how you quantify or prove or document the losses 
of livestock resulting from a particular predator. I can appreciate your 
emotional response and your father's when you perceived your loss. 

You attribute your losses to the golden eagle. Will you tell me how 
you can determine what predator or type of predator killed your 
animals? 

Mr. Flitner. Yes. First of all, we had these sheep in a particular 
area on agiven date and we would occasionally lose a ewe to natural 
causes. When first we saw the golden eagles, they started to move in 
and eat the ewes, which was no problem. That was fine. 

On May 20, a year ago, the ewes were to lamb and they began 
lambing. We noticed immediately that the eagles diverted from even 
the carrion that was left, the ewes that haa died, and we did not 
understand why. We had never had any previous experience with this 
type of predation from eagles. 

We started to fly the country- and ride in on horseback in an effort 
to see what was happening. This is when the incident took place in 
which I took my father out there with me. We started to mid car- 
casses of lambs with the marks on them. 



D,g,tze:Jb.GOOg[e 



100 

We had a man out there for cattle, because we run cattle and sheep 
tc^ether, and at one point in time — sir, I hesitate to mention eagles 
because I know very well how emotional an issue they are — this man 
saw an eagle come down and pick up one of these young lambs, take 
him up to an altitude of about 100 to 150 or 200 feet, his estimate, 
and drop him. The lamp dropped on the ground. Of course, that killed 
it. The eagle swooped down, picked him up, and took him away. We 
do not know how many lambs we did not see, but we have been in 
the sheep business long enough to know how many lambs should have 
been produced in that environment given the shape the sheep were in. 

We saw carcasses in the amounts that I have mentioned here. We 
tried to get into the area every 2 days and not disrupt the ^eep. 
This is our best estimate of what happened. 

I believe, in all sincerity and in all honesty, that it is a very con- 
servative estimate. 

Mr. Wampleh. I have one other quick question. 

Secretary Andnis in his memorandum, that has been discussed here 
today, among other things suggested: "In some cases, a return to 
traditional methods such as herders should be seriously considered 
and encouraged." 

We heard the commissioner from Texas here this morning say that 
that was not very practical in Texas. What about in Wyomii^? Would 
it be practical there? 

Mr. Flitner. No; it would not, sir. A sheep herder is almost as 
endangered as are sheep in this day and age. You cannot find one that 
is capable and competent to do the job. There are so many other social 
pn^^rams that are available to people to replace productive effort in 
our society today that many people who would normally herd sheep 
have gone into this tjype of program. 

It is nearly impossible to get them from overseas and across borders 
because that has been frowned upon by our society. It is extremely 
difficult to find anybody who would go out with a band of ^eep. 

We used to take two or three people who would take the sheep out in 
January or February and would come in the next March. There are 
not too many people in our society today that are willing to do that. 

It is not, in my view, unless there is a liberalization of the laws that 
prevent people from coming in from outside the United States, practi- 
cal to do. That is probably the only salvation. 

In fact. Congressman Wampler, it is becoming more and more diffi- 
cult in America today to even get the sheep shorn. There is tremendous 
pressure to keep Australian sheep shearers out. As a result of that, 
people who are trying to shear sheep and provide this service for what 
IS left of the sheep industry are having tremendous problems in the 
labor area. 

Mr. Wamplbb. Thank you, Mr. Chairman. 

Mr. DB LA Gabza. Thank you very much, sir, for your very forth- 
right testimony. 

Mr. Flitneb. Thank you, Mr. Chairman, and gentlemen. 

Mr. DE LA Gabza. The next witness is Mr. Charles Boothby of the 
National Association of Conservation Districts. 

We welcome you, sir, and will be happy to hear from you at this 
time. 



D,g,tze:Jb.GOOg[e 



STATEHEHT OF CHARLES L. BOOTHBT, EXECUTIVE SECRETARY, 
RATIONAL ASSOCIATION OF CONSEBVATIOR DISTBICTS 

Mr. BooTHBT. Thank you, Mr. Chairman, members of the com- 
mittee. I am Charles L. Boothby, executive secretary, Natiomil As- 
sociation of Conservation Districts. 

NACD represents nearly 3,000 conservation districts in the 50 
States, Puerto Rico, and the Vii^in Islands. Conservation districts are 
established under State statutes to develop and implement programs 
for the conservation of soil, water, and related resources withm the 
district boundaries. Districts are working directly with over 2.5 million 
private landowners and operators. 

Because of periodic and localized imbalances in predator-prey 
relationships in many areas of the country, conservation districts have 
become concerned about the animal damage control programs of this 
Nation. This concern is expressed in our policy position statements 
which follow. 

The advance of civilization has often created an imbalance of preda- 
tor-prey relationships in wildlife and has created conflicts in the raising 
of domestic animals. 

Although broad-scale, nonselective predator control programs are 
not ecologically sound and are in many cases uneconomic^, specific 
predator management programs, both on public and private lands, are 
Doth feasible and necessary. 

NACD supports predator control measures implemented within 
accepted principles of wildlife management for the purpose of main- 
taining proper predator-prey relationships. We believe that in some 
instances the use of chemical toxicants by trained professionals, 
particularly compound 1080, may be the most humane and economical 
method of predator control. 

We call for increased attention to the predator problem and ask 
the Federal Government to provide additional research into methods 
of control, increased assistance to individual producers plagued by 

Eredator damage, and continued reassessment of the wisdom of 
anning proven methods of control, keeping in mind the need for 
more emcient and humane predator man^ement programs toad 
procedures. 

We support the concepts of H.R. 6725, although we have some 
reservations about some of the specific provisions. We question 
whether it is a vehicle which will actually unprove predator control 
activities and effectuate actual improvements in predator control. 

The bill does not address the emerging issue of biological control 
of predators, an issue that needs greatly increased research and de- 
velopment. We recommend inclusion of provisions to authorize such 
research and development, perhaps as a section 3(a)(6), to read: 
"Undertake applied field research relating to biological controls and 
techniques, including the economic and environmental effects of such 
controls". 

An alternative would be to insert the words "and biological" foUow- 
ingthe word "nonlethal" on line 14 of page 3. 

The bill does not authorize a specific and separate appropriation. 
We believe that a separate appropriation would give the pn^ram the 
priority it deserves. If the funding of this prc^ram must be from 



D,g,tze:Jb.GOOg[e 



102 

funds diverted from other programs, we doubt if much progress will 
be made. 

We recommend the followii^ lat^uage: "Sec. 5 There is hereby 
authorized to be appropriated such funds as are necessary to cany out 
Section 3 of this Act." 

We do realize that the Department of the Interior does have a 
separate appropriation for animal damage control at present. 

Section 3(a) authorizes the use and additional research on the use 
of compound 1080 for animal damage control. This will, in effect, 
overturn recently announced Federal policy discontinuing research 
on the chemical. The language in the bill is, we believe, appropriate 
until such time as better control methods can be devised. 

Section 4 of the bill requires the Secretaries to submit yearly progress 
reports on the development and implementation of the prc^Tfon. We 
question whether such frequent reporting is necessary. Research takes 
time and results are infrequent. Assessment of control programs also is 
a longer term matter. We believe that biennial reporting would be 
adequate and is in keeping with the schedule proposed for the activities 
of the ad hoc committee provided for in section 3(b). 

It should be stressed that this program of animal damage control 
is necessary and will be conducted on both Federal and non-Federal 
lands. 

This completes our prepared statement. I would be glad to enter- 
tain any questions you may have. 

Mr. DB LA Garza. Thank you very much, sir. 

Mr. Wampler. I have no questions. 

Mr. DE LA Oarza. We appreciate your suggestions. I do not antic- 
ipate any great problem in addii^ "biolc^cal" to our bill. That is 
vray much appreciated. 

The reason for the nonappropriation is that we have some budget- 
time schedule problems. If this bill were to move, it has to move with- 
out impact on the budget beyond the time limit, but we appreciate 
your interest and that suggestion. 

I think that, with the committee, we can work out changes commen- 
surate with your excellent recommendations. 

Thank you very much, sir. 

Our next witness is Dr. James Bowns of Southern Utah State Uni- 
versity. We welcome your being here and all the excellent work which 
you have done in this area. 

We will be happy to hear from you at this time. 

STATEMENT OF TAKES E. BOWHS, RANOE ECOIOGIST, BIOLOGICAL 
SCIENCES, UTAH STATE TJNIVEESITT AND SOUTEEBH UTAH 
STATE COU^OE 

Mr. BowMS. Thank you, sir. 

Mr. Chairman and members of the committee, my name is James E. 
Bowns. I am a range ecolt^ist, sharing a joint appomtment with Utah 
State University and Southern Utah State College, where my responsi- 
bilities involve research which has included predator damage assefis- 
ment, teaching, and extension. 

I was a member of the Animal Damage Control Policy Study Advi- 
soiy Committee appointed by Secretary Andrus in 1978. I am pres- 
ently a member of the WRCC-26, Western Regional Coordinating 



D,g,tze:Jb.GOOg[e 



103 

Committee, entitled "Maoagement of Predators and Relation to 
Domestic Livestock," and I am the immediate past chairman of that 
committee. 

I have submitted my written testimony and I will now summarize 
my remark. 

Mr. DB LA Garza. Thank you, sir. Without objection, your full 
statement will B£pear in the record, 

Mr, BowNS. The livestock industry of the West is dependent upon 
rangelands for the majority of the livestock's forage. Predation is one 
of the most serious problems facing this industry on these lands. 

The losses reach levels which prevent proper use of rangelands and 

firoper utilization of forage. The rangelands are the world's largest 
and resource. They include approximately 47 percent of the land 
surface of the Earth, 63 percent of the contiguous United States, and 
86 percent of my home State of Utah, 

Physical features, such as rough topography, poor soils, lack of 
moisture, et cetera, prevent these lands from being intensively used. 
Their contribution is direct in terms of livestock production and indi- 
rect because vegetation management affects water yield, biological 
stability, and environmental enhancement. 

Livestock grazing is compatible with, and even beneficial to, other 
uses of the range and is a part of multiple use of the range and an 
important use of rangelands. Food production can be obtained from 
rangelands only through the grazing animal. These ruminants are 
able to convert plant materials to meat that would otherwise be 
wasted. 

They also provide other products, such as leather, wool, hair, lanolin, 
essential enzymes, and pharmaceuticals. Range livestock production 
requires considerably less cultural enei^y in the forms of labor, manu- 
facture of machinery, transportation, tillage, fertilizers, and herbi- 
cides for the production of fiber and food. 

This food production is complementary to humans rather than com- 
petitive. As world populations grow and the demand for grain and 
energy increases, there will be a greater shift to reliance on forage and 
less reliance on grain to produce food that ruminants are capable of 
supplying. 

Studies have shown that sheep and goats are more efficient pro- 
ducers than cattle. This is as a result of: Multiple births, faster growth 
rate, ability to fatten to choice — what we term grass fat — without 
grain, the ability to utilize steep rugged terrain and ranges with 
limited water, as Mr. Flitner indicated, and they utilize greater pro- 
portions of browse and produce a dual crop of wool or hair and lambs 
or kids. 

I would like to support a statement that Mr. Flitner made that on 
many of our western rangelands, the best use of those lands is with 
common use — sheep, goats, and cattle. 

Sheep and goat numbers have decreased and cattle numbers have 
increased during the past three decades. This has been lai^ely due to 
the cost of operations, lower market prices, and predation. Sheep and 
goats are also effective for the control and/or manipulation of vegeta- 
tion. Goats have been effective in maintaining shrubbery growth on 
firebreaks in California. The firebreaks are used for better fire manage- 
ment by breaking up the lai^e stands of brush. 



D,g,tze:Jb.GOOg[e 



104 

Regrowth following coiLstruction is immediate and abudnant and 
maintenance ^vith herbicides and mechanical equipment i^ difficult and 
costly. 

Goata have also been effective in controlling regrowth of treated 
gamble oak in Colorado. In Utah we have used goate to manipulate 
black brush and convert it to a form more palatable, digestible, and 
nutritious for cattle. 

Sheep have been used successfully to reduce sage brush density and 
rehabibtate seedings of grasses that we have throughout the West 
and to reduce herbaceous species and leave browse plants for deer. 

Sheep are also useful to remove certain herbaceous species, not 
desirable for cattle grazing, therefore releosii^ desirable passes. Goats 
are used, as has been mentioned today, extensively in Texas to con- 
trol woody plant growth. They can be used to control low-growji^ 
brush or as a followup control of browse. 

This hiol<^ical control of undesirable plants produces food and fiber 
and minimizes fossil fuel use. In recent years low mohair prices and 
predation have caused a decrease in goat numbers. That has also 
been indicated previously today. 

In recent years predator losses have contributed to entire flock 
liquidations, Mr. Flitner referred to that. 

On the fringes of goat producing areas, predators have increased 
to the point where reestablishment of goat herds will be diihcult. 

USDA studies also indicate that sheep and goat producers are being 
forced out ot the business because of predators. Discouragement be- 
cause of predator losses and frustration over restraints on control 
are common with sheep and goat producers. 

Losses to predators take several forms, the most obvious and 
dramatic being the direct killing of livestock, but other losses include 
reduced animal production because of molestation, reduced produc- 
tion because of efforts to evade losses such as increased incidence of 
parasitism because of close confinement — someone else will address 
that in more detail— cost of supplement feed, cost of gathering and 
treating animals follo«Tng predator attacks, direct costs of control 
efforts, reduced attention to other phases of farmers and ranchers, 
and probably the most serious, the inability and unwillingness of 
ranchers to produce sheep and goats in areas where they are well 
adapted because of excess predator losses likely to occur. 

This discussion has emphasized the predator losses to sheep and 
goats, but predation is also a serious problem with cattle. Cattle 
losses, however, are somewhat sporadic, regional, seasonal, and are 
not well documented at this time. This subject will be more thoroughly 
treated by other witnesses. 

It is the sheep and goat industry that suffers the greatest loss and 
has borne the greatest burden of justifying and conductii^ daniage 
control programs. Wildlife should also be considered in this discussion, 
as they benefit from proper grazing management. 

Careful planning, including specialized grazing systems and vegeta- 
tion manipulation, can increase returns from both wildlife and live- 
stock. Predator control programs designed to protect livestock can also 
btmefit wildlife. Studies have shown that decreases in coyote popula- 
tions have increased in increased numbers and diversity of other mam- 
malian predators. 



D,g,tze:Jb.GOOg[e 



105 

Coyote predation has also been shown to be a significaDt factor in 
the reproductive success of antelope, mule deer, white-tailed deer, 
turke>^, and bighorn sheep. Some biologists feel that there is little 
doubt that predators can exert s^nificant effects upon populations of 
lai^ game animals. 

In summary, good range and Uvestock management is beneficial to 
the range resource and livestock and wildlife. A variety of products 
that are useful to man can only be obtained from rai^lands through 
the grazing animal. These products can also be obtained with a con- 
siderable saving of energy compared to int«nsive agriculture. 

Livestock and wildhfe can be efficiently produced on our western 
rangelands only with proper management and husbandry practices 
which include an effective predator management program. The pro- 
gram shoulil include all methods to protect livestock, including herders 
where feasible, fencing, penning at night, shed lambing, et cetera. 

Policymakers should be aware, however, that in general producers 
currently employ all of the available and practical nonlethal and non- 
capture methods. Unless these methods are supplemented by the 
removal of predators, particularly in sheep, goat, and cattle areas, the 
predators respond by chatting their killing patterns or moving to 
other ranches. 

Effective control of predation in the Western States requires the 
application of all possible methods of control including selective toxic 
chemicals and other methods as appropriate to local situations. 

I appreciate the invitation to speak to you today. If you have any 
questions, I will be happy to respond to tnem. 

Mr. DE LA Garza. Thank you very much. Your full statement will 
be included in the record at this point. 

[The prepared statement of Mr. Bowns follows;] 



D,g,tze:Jb.GOOg[e 



BTiTmnMT Of ML. JAMES E. BOWNS, RAHGE ECOLOGIST, UTAH STATE DXIVERSIIT, „ 

LOGAK, UTAH, AUD SOUTHEM UTAfl STATE COLLEGE, CEMl CITT. VtiS "Jl^ 

Predatlon on livestock In the Hestern Unlttd States Is oni of tht mst 
strlous probleas facing the range livestock Industry. Predatlon causes very 
serious econonlc losses to nany, producers forcing the abandonaent of a sub- 
stantial nuaber of livestock operations. These losses also reach levels 
■hich prevent proper use of range land, and the proper utIllHtlon of fOrag* 
resources by livestock. 

Range lands are the worlds largest land resource accounting for approx- 
iMtely 47S of the land surface of the earth, S3t of the contiguous IkilbM 
Stites, and 861 of qy htwe state of Utah. These range lands are not suitable 
for Intensive land use because of rough topography, severe teMperatures, 
rocky, shallow or salty soils, or lack of rootsture. The contribution of 
these rangelands to national and world food supplies fs direct. In tern of 
the production of livestock products, and Indirect since vegetation Mnagenent 
affects water yield, biological stability and envi romeental enhancenent. As 
populations Increase our rangelands will be subjected to Increase denands for 
food production and other uses (Thomas, 1980). 

In addition to the products produced, through livestock grazing this use is 
beneficial and often required as a tool to maintain desirable ftirage conditions 
for wildlife. Livestock grazing can also be coapatable with, and even bene- 
Plclal to, other uses and values of the range [Anderson, 1980). 

The Society for Range Management, an International organization of range 
scientists, range ecologlsts, range managers and ranchers, supports the con- 
cept of multiple use an4 livestock grazing as an Irwortant use of rangelands. 

Grazing by animals is the only way that millions of acres of rangelands 
can be harvested for food production. These animals, rmlnants, are a special' 
class of animals which Include cattle, sheep, goats, deer, elk, and buffalo 
that have, as part of their digestive process a microbial fermentation stage 



D,g,tze:Jb.GOOg[e 



in Hhtch plant MterlaU such as grass are broken down to usable nutritional 
forms. This unique ability enables runinants to convert, to aeat. bIIIc or 
other hiaan food, many plant miKerlals and industrial byproducts that Muld 
otherwise be wasted. (CAST. 1975). 

In addition to producing food, runlnants also provide other products useful 
toman such as leather, wool, hair, lanolin, essential enzymes and phamaceu- 
tlcals such as Insulin {CAST. 1975). 

Range livestock production requires considerably less cultural energy 
(labor, machinery, transportation, tillage, fertilizers, herbicides, etc.] for 
the production of neat and fiber than that required In confined fattening pro- 
ceedures [Cook, 1976). Food production by nninants Is also conplementary to 
hunans rather than conpetltlve (Hodgson, 1976). As the population grows and 
Bs world demand for grain and energy increases there will be a shift to greater 
reliance on forages and less reliance on grain to produce the foods that rum- 
inants are capable of supplying. 

Mhen conparing the relative efficiencies of the various classes of rum- 
inants It has been found that sheep ar« considerably more efficient than cattle. 
This is i result of multiple births, faster growth rate, and the ability to 
fatten to choice meat grade on range forage without grain [Cook, 1975). Sheep 
and goats are also mare efficient on many western rangelands because they are 
well adapted to use steep, rugged terrain, ranges with United livestock water, 
and utilize greater proportions of browse and other species not acceptable to 
cattle. 

Another benefit conferred by sheep and goats Is the dual crop of waol or 
nohair, and lambs or kids they produce. However prcdatlon, cost of ORtratlwit 
ind lower market prices have caused sheep and goat nuabers to give way to in? 
creased cattle numbers during the past 3 decades. TIm Mst effective use ef 



D,g,tze:Jb.GOOg[e 



rainy rtngelands, hOHevtr, can b« accsaplUhBd Hith coann uss by cittl*, 
sheep, and goaU (Cook, CM. I9S4). 

Sheep and goat! are also very effective In the Mntral and/or raanlpulatlon 
of vegetation. In southern California finl breaks are constructed in the 
parral type to break up the vegetation for better fire wnageaent and to 
mtate protection of urban areas and wotersheds. Regrowth from construc- 
n of these firebreaks Is Imedlate and abundant and natntenance Is ilfffl- 
t and costly. Goats are currently used to control this regrowth of thmbt 
goat 9raz<ng is an alternative to herbicides and other control iiethods 
[Green, et al.. 1979), 

Goats have been effective tn controlling ganbel oak In Colorado as • 
folloHup treatnent to nechantcal control (Davis et al.. 1975). Goats have 
also been utillted In Utah to manipulate blackbrush and convert It to a forn 
nore palatable, digestible, and nutritious for cattle use {Provenia, 1980), 

Sheep are also being used to reduce sagebrush density and rehabllitat* 
grass seeding and to naxlnlze utilization of herbs and leave broDse plants 
for deer winter forage (Jensen, et al . , 197?). Sheep have also been successful ■ 
removing certain herbaceous species not desirable for cattle grazing and there- 
fore releasing desirable grasses. 

Goats are used extensively in teia* to control MOOdy plant gronth. 
These animals can be used to control 1 OH-groid ng brush or as fo11oH-up Main- 
tenance control of sprouts on brush that has othemlse been treated for Initial 
control. Repeated deftillatfon of t^e plant will either control its growth and 
spread or k111 it (USDA. 1964). 

Goat browsing to control brush makes use of land and resources to pro- 
duce food and fiber products that mlnlnlze fossil fuel use and that are not In 
direct conpetltlon with lun for food and plant production. 



D,B,i..ab,Google 



Goat numbers. In Texas, fluctuate as ■ result of product price fluc- 
tuations and weather Influences. Loh nohalr prices In the >1d IMO's and early 
1970's were the major reason that angora goat nunbcrs dacreased, but predator 
problems were i strong second factor. In recent years losses to predatlon 
have contributed to entire flock liquidations (Kensing, T978). In many 
fringe areas predators have Increased to a point where reestablishment of 
goat herds would be difficult. 

Studies have shown that sheep and goat producers are being forced out of 
business because of predators. DiscourageMent because of predator losses and 
frustrations over restraints against strong corrective actions has been fOund 
among former producers as we11 as those stUI in business (Gee, et a1.^1977). 

The most Dbvious and dramatic loss frmi predators is the direct killing 
of livestock, but losses occur In several other ways. These Include: (1) re- 
duced animal production because of aolestatton, (Z) reduced production be- 
cause of efforts to evade losses. An example of this would be parasite infes- 
tations as a result of close confinement. (3) supplemental feed for anlMls 
under confinement, (4) gathering sheep scattered by predator attacks and 
treating animals Injured by predator attacks, (5) direct costs of central 
efforts, (G) reduced attention to other phases of the farm or ranch •peratlon, 
and perhaps the most serious, [7) the inability or unwillingness of ranchers 
to produce sheep and goats In areas where they are well adapted because af the 
excess predator losses certain to occur (Uade and Connolly. 1980; Shclton and 
Kllndt, 1974; Hesse, 1974). 

This presentation has ewhastzed the impact of predators on sMep and 
goat operations, but predation is also a serious problem with cattle. TIm 
cattle Industry is thought to suffer the greatest direct financial last frwa 
predation but these lasses are soMwhat sporadic, scasoul . and regloMl and 



D,g,tze:Jb.GOOg[e 



arc not well docunenUd. U)«n predction ts «xpr«(i«d is ■ ftjHctlm of cca- 
nomic value It \s the sheep Industry ahlch suffers the ireitest lost. It It 
also the sheep Industry that has borne the greatest burdtn of Justifying and 
conducting dawige control prograas (Shtlton and Hade, 1179). 

W11d11fe also benefit froa proper graitng nanagncnt. Studies show that 
with careful planning including specialized grazing systems and vegetation 
manipulation rangeland resources can be oanaged to increase returns fr«M both 
livestock and big game animals (Bryant et il., 1979). This is true for non- 
gimc as well is game species. 

Predator control programs may also directly benefit wildlife. When coyote 
numbers declined significantly between 1941 and 1951 significant Increases in 
the populations of other maionallan carnivores were observed. This Indicates 
increased numbers of and diversity of other predators when coyote populations 
are suppressed (USDI, 1978). Studies have also shown that coyote predatian is 
a significant factor In the reproductive success of antelope, deer, turkeys, 
and bighorn sheep. Some biologist feel that there Is little doubt that pre- 
dators can exert significant affects upon population levels of large gipw 
animals (Uinkler, 1978). 

In suimary, good range and livestock management Is beneficial to the land, 
livestock and wildlife. A variety of products that are useful to man can only 
be obtained from rangelands through the grazing aninal. These products can 
also be obtained with a considerable saving of energy coopared to Intensive 
agricultural operations. Livestock and wildlife can be efficiently produced 
on our western rangelands only with proper management and husbandry practices 
which includes an effective predator management program. This program should 
include all methods to protect livestock, including herders where feasible, 
fencing, penning at ntght, shed lambing, etc. Policy makers should be aware. 



D,B,i..ab,Google 



however. th»t, in general, producers currently employ all these available and 
practical non-lethal, non-capture nethods. Unless these measures are sup- 
ptenented by the reaoval of predators, particularly in sheep, goat and calving 
areas, the predators respond by changing their killing patterns or moving to 
other ranches. Effective control of predation in the western states requires 
application of all possible nethods of control Including selective toxic 
chenlcals and other methods as appropriate to local situations (URCC-ZE, 19Sa). 



D,g,tze:Jb.GOOg[e 



e C4t*d 
Livestock Grazing - A Capctlng ust of Public 

Bryint. F.C. , H.H. Kothiann, and L.B. Herrlll. 1979. Diets of SlMcp. 
Angora Goats, Spanish Goats and Uhlts-talled Deer under Excellent Kanie Cen- 
ditlons. J. Range Manage. 32:412-417. 



I by Sheep and Cattle. 



e Heat and Fiber 



Gee. C.K., R.S. Kagleby. D.B. Nielsen, and D.H. Stevens. 1977. Factors 
in the Decline of the Western Sheep Industry. USDA Ag. Res. Ser. Report . 
No. 377 31 p. 



197G. Forages, Ruminant Livestock, and Food. Biosclcnce 



Kensing, R. )97S. Econonics of Angora Goat Enterprise 
Sta. Report 9 p. 



Provenza, F.D, 1980. Personal ( 

Shelton, M. , and J. Klin 
and Certain Livestock and Gam 
M-114e. 11 p. 

losses; A Serious Livestock 
n tkirld Food Productlwi. 



HRCC-Z6. 1980. A Response to Secretary Andrus' Policy Stateaent Per- 
taining to the Aniaal Danage Control Program. Western Regional Coordinating 
Comnlttee (WRCC-2G) Report. 



D,g,tze:Jb.GOOg[e 



113 

Mr. DB LA Gahza. Mr. Wampler? 

Mr. Wampler. I have brief questions, Mr. Chairmaa. 

Dr. Bowns, I want to thank you for comii^ today and sharing this 
statement with us. 

I think your credentials are well known and certainly you are a 
recognized expert in the field in which you testified. Are you satisfied 
that the losses to the sheep and goat industry from predation are 
accurately and well documented and are as they have been presented 
to us today? 

Mr. BowNS. Yes; I feet that they are. It is a tremendous problem 
in the West. 

Mr. Wampler, I ask you also this. A portion of Secretary Andrus' 
memorandum reads: 

There will be no further research and development of potential uses of oom- 

Eound 1080. However, research may be continued on other toxicants that do not 
ave secondary effects, are selective and humane. 

Do you agree with the conclusion that Secretary Andrus reached 
on the question of the need for further research on compound 1080? 

Mr. BowNs. No, sir. I do not agree with that, I think that research 
should continue, particularly the work that they are doing on the 
toxic collar and probably beyond that. I do not agree with the ban on 
research with 1080. 

I would be all for new toxicants if they could be developed, but it 
appears that there are none on the horizon at this time. 

Mr. Wampleb, I gather from your statement that you would feel 
that whatever research capability or resources the Department of the 
Interior, particularly the Fish and Wildlife Service, has should be 
devoted to further research on the uses of 1080 rather than going into 
some areas that may not be nearly as promising. Is that correct? 

Mr. Bowns. Yes, sir. I think there is a great potential for the use of 
1080 and I think that research should continue, 

Mr. Wampler. Let me say also, as I indicated at the outset, you 
have had many years of experience working in agricultural research 
and extension and you feel this would be a h^h priority item, not only 
for the Federal Government but for State and local governments to 
consider as they set their priorities for research to address this very 
serious problem. Is that so? 

Mr, Bowns. Yes, sir. I do. 

Mr. Wampler. Thank you. 

Mr. DB LA Garza. Thank you veiy much. Dr. Bowns, for this very 
excellent scientific appraisal of the situation. From my personal view- 
point, your analysis oi the situation is that except for the involvement 
of government, the sheep and goat industry would be alive and pros- 
pering but it suffers from the limitations that have been imposed by 
government. 

Farmers and ranchers have not been able to take care of their herds. 
I think that the balanced way in which your statement presents the 
issue is certainly one of the most helpful that we will nave in — we 
hope — arriving at a solution to this problem. We thank you tor that 
presentation. 

Mr. Wampler? 



D,g,tze:Jb.GOOg[e 



114 

Mr. Wampler. Dr. Bowns, let me be sure that I understand the 
thrust of a statement that you made. I believe I understood you to 
say that in your opinion there is no other toxicant available at the 
present time that would be as effective as is 1080 for the control of 
predators. Was that your meaning? 

Mr. BowNS. Yes, sir. That is my understanding. There are toxicants 
they are looking at but nothing that has the promise that 1080 has. 
We have years and years of experience with 1080 that we do not have 
with these other compounds. 

Mr. Wampler. So, it would be fair to say that many of the other 
toxicants that may be suggested or that may offer some nope probably 
would require as much or more reqsearch to develop as would lie 
taken to continue the work on 1080. Would that be a fair statement? 

Mr. BowNS. I would say, yes. I would say they would require more 
research to develop than would 1080. 

Mr. Wampler. We could, therefore, assume that it would cost more 
money to start in new fields of research rather than to complete that 
which is currently under way as it relates to 1080. 

Mr. BowNS. I would assume that. Yes, sir. 

Mr. Wampler. Thank you. 

Mr. DE LA Garza. Are you acquainted with the studies being made 
of the toxic collar? 

Mr. BowNS. Yes, I am. I know Guy Connolly and Dale Wade very 
well. They are the ones actively involved in that research. I have 
followed it through the years. 

Mr. DE LA Garza. From your vantage point in the field — and I am 
sure that you have studied and Einalyzed their research — what would 
be your professional recommendation as to the use of the toxic collar 
with the 1080 compound? 

Mr. BowNs. I think it would be a very effective tool under certain 
conditions. I do not think it is a panacea or a cure-all, but I think it 
would be a very effective tool used in conjunction with other lethal 
methods as well as good rai^e management and animal husbandry 
practices. 

I think we need a good integrated program using all of those things. 
I think it is a very useful tool and I think it is at uie point now where 
it could be used operationally. 

Mr. DE LA Garza. We appreciate that very much, sir. Thank you 
very much for beii^ here. 

Mr. BowNS. Thank you, sir. 

Mr. DE LA Garza. Our next witness is Mr. Laird Noh of the Na- 
tional Wool Growers Association, Salt Lake City, Utah. 

We welcome you. We appreciate your being here and we will be 
happy to hear from you at this time. 

STATEMENT OF LAIBD HOH, CHAIRHAN, ElTTIfiONHEIITAI COK- 
UITT££, NATIONAL WOOL OBOWERS ASSOCIATION AND UTAH 
WOOL GKOWERS 

Mr. Noh. Thank you, Mr. Chairman and Mr. Wampler. We do 
appreciate the opportunity to be here. 

I am today representing the National Wool Growers Association 
and also the woolgrowers ot my own State. I am a sheep producer and 
feeder cattle producer in south central Idaho. 



D,g,tze:Jb.GOOg[e 



115 

I also serve as cochair of the Sheep Producer Environmental Com- 
mittee, which is a committee of western eDvironmental interests and 
sheep producers involving six States in the West. I believe Mr. Symms 
has suomitted for the record a letter which that committee omcially 
drafted to Mr. Greenwalt expressing the sheep producer environ- 
mentalists' concerns about the Andnis animal damage control 
program. 

With your peimission, I will submit our formal testimony for the 
record, summarize it, and add a couple of comments. 

Mr. DE LA Garza. Very well, sir. Your full statement will appear in 
the record. 

Mr. NoH. Over the years the Department of the Interior has indeed 
undei^one a change in attitude toward their dual responsibilities of 
wildlife management and livestock protection. The 1931 Federal 
Animal Damage Control Act mandated the Secretary of Agriculture 
to control the predution of livestock, and in 1939 that responsibility 
was transferred to the Secretary of the Interior. 

In the early 1960's Interior began to disregard this mandated 
responsibility and to place their wildlife resources at a higher priority 
than the protection of the agricultural resource. The effect of the 
shifting priority has been programs designed and nurtured to propa- 
gate lai^e numbers of coyotes at the expense of sheep and other prey 
species. 

We think that is a very important point. 

Another point we think ought not to be overlooked is that hope 
held out in the area of nonletnal methods research. In 1966, 14 years 
ago, Assistant Secretary of Game, Fish, and Parks, Stanley Cain, 
testified before a Senate hearing as follows: "We will find answers 
through research on repellants, fences, and scare devices," 

Then, again, in 1973, Assistant Secretary of the Interior Nathaniel 
Reed said : "A strong research effort will produce techniques that are 
both better and cheaper." 

Now, is there any wonder that we have become dubious about non- 
lethal research. We have seen little yet of a positive nature. We 
thought perhaps we had not been informed of developments of these 
13-year research efforts when we first read Mr, Andrus' policy state- 
ment, so in January tlie National Wool Growers Association requested 
from the Fish and Wildlife Service a list of appropriate livestock 
husbandry techniques which we might apply, as mentioned in the 
Andrus proposal. 

Mr. John Rogers of that Department wrote back 2 months later: 
"We cannot provide such a list as requested in your letter," 

There is no point in getting anybody too excited about these 
panaceas. 

We would respectfully suggest that you consider the language in 
this bill be broadened to specifically include the use of lethal control 
methods on public lands. Executive Order 11643, issued by President 
Nixon in 1972, banned the use of toxicants on Federal lands and in 
Federal programs. 

Federal lands are very important to sheep production and other 
livestock production. Subsequently, EPA, under the FIFRA, can- 
celed the use of toxicants for use by anyone anywhere. 



D,g,tze:Jb.GOOg[e 



116 

In light of recent data concerning compound 1080, we believe 
that these restrictions on public and private lands are arbitrary 
and unnecessary. Therefore, we respectfully request that you give 
consideration to some language to speak to the public lands question. 

Both the Executive order and the environmental protection law 
contain provisions for emereency use of toxicants. Criteria for emer- 
gency use call for an annual livestock loss of 12 percent or more. 

According to the study appended to my statement, one-third of 
the reporting 32 States had losses exceeding this figure in the years 
1972 thmogh 1978. The States of Texas, Wyoming, Montana, and 
others have filed for emergency use on more that one occasion. The 
bulkiness of the procedure is demonstrated by the necessary approval 
of these emei^ency requests by the Secretaries of Interior, ^riculture, 
HEW, and the EPA. 

If ever a bureaucratic nightmare existed, and granted there are 
many, this is certainly a classic. 

Despite these filings, not one emei^ency request for predator 
control has ever been approved under the Executive order, although 
two such requests sliced very handily through the redtape to protect 
from coyotes and predators the whooping crane and Aleutian geese. 

It is these ty^s of frustrating inequities that fire the enthusiasm 
for the so-called Western Sage Brush Rebellion, or more preferably, the 
Sage Brush Bill of Bights. Westerners would prefer to take their 
requests to State governments rather than to face such senseless 
review by Federal agencies. 

Mr. Chairman, I have been at this business too loi^ now and tJiis 
business has been in an awful turmoil since the Executive order 
of 1972. I suppose, if we have learned one thing, certainly out West, 
it is that we cannot effectively manage our natural resources and our 
wildlife resources with fantasy and wishful thinking and people 
who have no solid experience in now that ought to be done. We cannot 
do that successfully any more than you can cure the disease of cancer 
with a patent medicine program, however much we might wiab it 
to be that way, it just does not work. 

It is an awful irony, for instance, that there are literally dozens of 
toxicants readily available to any frustrated rancher which will 

Eoison coyotes. Compound 1080 was chosen by the scientific community 
ecause of its environmental qualities, not because it effectively 
kills coyotes, which it does. 

Yet, here we have environmental considerations which are blocking 
the use of the product while dozens of things — as ranchers lose confi- 
dence in a professional program— are readily available. 

The trouble with all the other products is that they do not just 
take care of coyotes, they take care of just about anything else as 
well. 

The National Wool Growers Association has not, until now, favored 
any kind of transfer of responsibility to Agriculture, We realize the 
coyote is a wildlife resource. We felt that perhaps Interior would 
except its responsibilities to agriculture, but they nave not done so. 
Repeatedly they have not done so. 

Time and time again the opportunity has been provided and again 
and again they have failed. 



D,g,tze:Jb.GOOg[e 



117 

The morale of the animal damage control people, we feel, is a 
disaster. The morale of the livestock community is a disaster. Any 
kind of organized professional animal damage control program is 
very rapidly disint^rating and perhaps has already passed the point 
of no return. 

State associations are passing resolutions for the establishment of 
State programs. Individual ranchers are hiring their own individual 
animal damage control personnel. 

We really see no route at this time other than to find some sort of 
strong new direction for the program. We certainly encourage the 
efforts that you are making. There is no doubt that something iias to 
be done. 

I do not find, in my travels, a single State wildlife management 
agency representative in the West, or any trained wildlife biologist, 
who has knowledge of predation by coyotes, inside or outside of the 
Interior Department, who agrees with this new policy put forth by 
Secretary Andrus, which policy was designed to solve the problem 
once and for all. It just has not. 

We thank you very much for your efforts to find some solution to 
the problem. Clearly, something has to be done if it is not already too 
late. 

Mr, nB LA Qarza. Thank you, sir. 

Your full statement, without objection, will be made a part of the 
record at this point. 

[The prepared statement of Mr. Noh follows:) 



D,g,tze:Jb.GOOg[e 



C of 

Bafora ths Houa* Co^d.t:taa on Agzicultuxa 

Sub-Co^d.tt*B on Dapartaant Invaatigatloo 

Ovaraigbt: & Raaaaicb 

At Haaxlua on H.R. 6723 

April 16, 19W 

Mr. Chalrsan and nwibcTa of tb* CoMilCCae, I ■■ La^-i^ llOb, 
• aheap ralaer froa Kli^arlgr, Idaho. Z •■» alao ChalTaan of 
tha National Wool Gtemtra Aaaoclatlan'a^^&MnBaatal Co^ttaa. 
I •■ hara today to apaak on babalf of tha ll.t,000 aha^ and 
laiab growara in the United States.^ 

The national Wool Growara Aasoclatlon la a fadaratlon of 29 
nembar assoclatlona. My asBoclstlon ia the oldest naclooal 
l-lveatock organlxaclon In the United States — organised In K65. 
For the past 115 years we have sought to gain equitable treatnent 
for our agricultural enterprise on auttera affecting It. Our 
progTSii eofihasla In recent years has bean the laaua «c are baT*. 
to discuaa today- -predator control. 

We know that the subject of animal danage control arouaaa 
enotlona and Is aurrounded by controvaiay. But we also raaliaa 
the absolute necessity pt a pcograB to protect our livestock froa 
the ravages of predators — If we Intend to maintain a viable sheep 
industry In the United Statea. We believe an effective and 
environmental ly safe predator control progran la embodied in H.R. 
6725; and we conplinient you for your work. 

In 1959 we had 32 million sheep in the United States. 2 in 
1969 we had only 21 million sheep In the United States. 3 in 1979 
we were down to 12 million head.^ Thia precipitous declloa In 
the number of abeep and aheap ranchers was a combination of 
aeveral factors. Including: economics, man-made fibers, climate, 
reduction In grailng allotoents and severe losses to predators. 
However. Just this laat year. In 1979. Cbla trend waa reversed. 
For Che first time In 20 yeara sbeep mimbera increased In the 
United Statea.^ Granted, the increaae was small, about 2% percent, 
but It waa viewed by people In the aheep industry as a significant 
achievement. It deaonstratea that there la a coatlnulng Intereat 
in, and an economic purpoae for, growing lamb and wool prodocta 
In this country. 



D,g,tze:Jb.GOOg[e 



Ic 1b slgnlflGan^ houcvai; to look closely at the atatlstlca 
on this IncTsaae in numbera. The average flock aise In the atates 
not shoving an Increase in numbers was 221 head. The avaraga 
flock alse In the states shewing an Inciease waa 94 head. The 
laiab loss in those 12 atates not showing a decreaaa waa 816,000 
haad. The laob loaa in the 19 states shewing an Increase waa 
608,000 heed, or 26 percent leas.^ Thus the increase In nunbers 
ia tied to states where amaller, Bore confined production 1* 
opereble. In statea intere forage, terrain and other factors dic- 
tate a larger scale of operetions, the lossaa continue to be aub- 
atanttal. He are pleaaed with the increase In sheep numbers, but 
we iBuat: not be lulled into e false sense of security. The 
threatened loaa of these larger operations will reverberate through' 
out Che Induatry resulting In a leek of suppllea and equipnent, 
health care products, markets, crenaportatlon end other aupportlve 
Industry factors. Stabilisation of the induacry depends on the 
continued detOTBlnatlon of people who husband sheep for a Living 
and the help of leadara like yourselvea. 

There ere other continuing problems, but the loss of sheep 
to predator a- -primarily the coyote--lB anong the most serious. In 
1978 the loaa of abeep and lambs by predation In my bone state 
of Idaho waa valued at over $3 mllLion.' This figure ia small In 
comparison to the value loss in Texas of $16 million, or California 
et 99 million, but It does repreaent 14 percent of the gross 
income of Idaho aheep and lamb producers. Nationwide the value ' 
la almost $98 million. ^ As an industry, our loaa may not be as 
greet es that incurred by Chrysler Corporation, but aa a pcrcntage 
of the totel gross income from the sale of aheep end lamba. It 
amounted to juat over 18 percent. It Is our contention tliet Che 
sheep husineaa cannot continue to incur economic losaes of this 
acope, particularly tn the "decreasing" atetea, and aeintainits 
ecMumlc viability. 

Mr. Chairman, 275,000 pounds of lamb goes across American 
tables every day in thla country,^ The 1978 lose of 28 sdllioa 
pounda of lamb represents enough lamb Mat Co provide teble food 
for 220 million Amerlcang_£or_aa additional 32 days each year,^ 



D,g,tze:Jb.GOOg[e 



s Juscifj auch a waaton and urniacessarj loaa of food 
sa. Ac a palnf In tins when domestic and world food dsaands 
are increasing. It la inconceivable Co wasteU thouaand ton* of 
neac intended £or human consumption.^'- The opportunitjr to staa 
this waste la at hand, and we applaud your interest to assist 
us with this effort. 

Over the yeare the Department of Interior has undergone a 
change In attitude toward their dual reaponslbllitles o£ wildlife 
oenagement and livestock protection. The 1931 Federal Predator 
Control Act aendated the Secretary of Agriculture to control the 
predatlon of livestock to protect our food and fiber base. In 

1939. Chat respohaibllity was transferred to the Secretary of 
Interior. In the early 1960's, Interior began to dlaregard chls 
nandated responsibility and to place Chelr wildlife resources at 
a higher priority. The effect of this shifting priority has bean 
prograns designed and nurtured to propagate large nunbers of 
coyotes at the expense of sheep and other livestock. The result 
is evident In the Increasing loss figures. 

Prior to the completion of the Environmental topact Study on 
the Animal Damage Control program, our Association eskad for equal 
consideration within the Department of Interior for programs re- 
lating to livestock protection snd to wildlife msnagement. Ue had 
hoped that the Secretary would recongiie the iiq>ortance of a bal- 
anced approach. Apparently he didn't, because on November 8th 
Hr. Andrus announced a policy that was solidly biased in favor of 
predatory species. Ue felt that our stance waa reasonable, and 
our indications from professionals in the Fish and Ulldllfe Service 
were that an equitable approach to the problea of predation would 
be sought through the E.I.S, process. Instead, several of our 
most effective tools are scheduled to be stripped from the prograa, 
and we presently find ourselves in a serious dileona — on* of 
increasing predation end reduced control techniques. 

You bsve addressed this problem in H.R. 6725. We feel this 
Icgislstion, when enacted, would result in significant reductions 
In annual loasaa. He support the use of proven lethal and non- 
lethal aolttal damage con trol devicea, methods and chemical 



D,g,tze:Jb.GOOg[e 



coxicantf. Wb «ncoura8e extended reeearch acctvltlea In letbaL 
and noiflachal control technlquaa, as addresseil In the BILI under 
Section 3. 

In tha acea of non- lethal leaeaxch, I'd like to point out an 
tteia oC concern. In 196G, 14 yeara ago, Aaalatant Secretary of 
Game, Flah and Parka, Stanley Cain, testified before a Senate 
bearing as followa: 'Ve will find answers through research on 
repellents, fences and scare devices." Then again In 1973, 
Assistant Secretary of Interior, Natbanlal Reed, testified, "A 
strong research effort will produce techniques that are both better 
and cheaper."^ Is there any wander we are dubloua about the 
non-lethal research. We have aeen little yet of e positive nature. 
He. thought perhaps we had not been Informed of the developments 
of this thirteen years of research. In January we requested from 
the Fish and Wildlife Service a list of "appropriate llveatock 
husbandry technlquea" as waa mentioned In the Andrus proposal In 
November. A Mr. John Rogera wrote back two months later, 'Sre 
cannot provide a list as requested In your letter." 

He conclude that despite a long tarn and extensive research 
effort, very little success baa been demonstrated In the non-lethal 
area. Ihls does not mean we oppoae further research In thla area, 
rather as I steted earlier, we support it. But It doea demonstrate 
tbe need fox continuing use of exlatlng lethal techniques as 
addressed In H.R. 6723 until the non-lethal area is developed, 
tested, and proven to be practical. 

Expert teatlaony at thla hearing will support environmental 
and functional aapacta of the lethal technlquea. He believe that 
this data will stand up under intense scrutiny. We suggest that 
the language In H.R. 6725 be broadened to include the use of 
lethal control methods on public lands. Executive Order IIM3, 
Issued by President Nixon In 1972 banned the use of toxicants on 
federal landa or In federal programs. Subsequently E.P.A. under 
the Federal Insecticide, Fungicide and Rodenticide Act canceled 
the uae of toxicants as a predaclde by anybody, anywhere. In 
light of recent date concer ning Coi^ound lOK), we believe that 
' " " " I 



D,g,tze:Jb.GOOg[e 



th«ac reatrictions on public and private landa ara arbitrary and 
imnecaiiary. We suggaat Section (1), sub-aactlon A. Include the 
language "on public and private landa." 

In a recent letter to our Aaaoctatlon, Interior dlaalaaea 
the uae o£ Coopound 1080 becauae It was "concroveralal". We 

don't believe Chat controversy Is a proper measure □£ the chenical's 
effectlvenesa or safety. Moreover, we believe It la the prcfea- 
slonal respoasiblllty oC Interior officials to provide the public 
factual data on the toxicant In order that an objective analysis 
on Che uaa of thla confound can be made. 

We are further concerned that Interior, in this ssme leccer, 
atate that they fcer "costly litigation" If they continue their 
research on 1080,'^' He'd like them to doeuaent their rationale. 
We feel the results will withstand a legal test, if such is 
actually fori:hcoiiilng. Interior is hiding behind Che shroud of 
influence of persons who have liccle understanding of Che acope of 
the predator probleo, and who exhibiC a cspricioua attitude toward 
Che food and fiber base of this councry. 

Boch Che Execuclve Order and the E.P.A. low conCalned pro- 
visions for "eaargeney use." CriCeria for eaergency use called 
for on annual loss of 12 percent or nore. One-third of the 
reporting 32 atatea had losaea exceeding this figure in the 
years 1972 through 1978. The atatea of Texas, Wyoaing, Honcana and 

ochers have filed for emergency use on acre Chan one occasion. 
The bulfclness of Che procedure Is deoonsCrated by Che neceaasry 
approval of these emergency requeata by Che Secrecarles of Interior, 
Agriculcure, Heslch, Education and Welfare and the £nvlionaencal 
Protection Agency. If ever a bureaucratic nightnare exiated, 
this is a clssalc. Despite these filings, not one eaergency 
requesc for predator concrol was ever approved under cbe £xecutlv« 
Order, although two sliced handily through the red cape co proteot 
the whooping crane and the aleuClan geese! 

IE la chese cypes of fruscrstlng inequities that fire the 
entbuslaaii of the so-called Sagebrush Kebellion, or preferably, 
the Ssgabmah Bill of Rights. WesceriMrs would prefer co cdce 
tiMlz requesty to state goveftTsnta rather then face a contlauom 
McwelMs 4||||^lliB bj fe^Pl ageoclea. 



D,g,tze:Jb.GOOg[e 



123 

All in all, Mt. ClulrjMO, w« b«llev« that Interior ali^ly »od 
unequivocally does not Incend to caatn>l predatora or carry out a 
prograii aa Mndated by the 1931 Act.^' Likewise, »e believe that 
H.R. 6725 would reaffirm and re-establish a comslttmeot In support 
of a viable predatory anloal control progran. It alio would 
Interject the production orlencatlon of the O.S. Departiaent of 
Agriculture, • laich needed Input. 

As I mentioned earlier in my statement, the sheep Industry 
ia in a positive position to continue Its growth and expansion. 
The National Wool Crowera Asaoclation la dedicated to that end. 

We don't relish being characterised aa ■nvlranaBntal despollers, 
and we are convinced that the tastlaony you will hear today, or 
already have heard will demonstrate that we are not. We are 
concerned about our livelihood. We are concerned that on one 
hand killlons of dollars have been spent on productive research 
to increase birth rates of sheep, to Increase lamb weights snd to 
provide a higher quality wool clip; and on the other hand, the 
benefit of this research Is being wasted through the destruction 
of the product. Ue are concerned beceuae of the tenae International 
situation. At the outbreak of the second world (far, and again In 
Korea, the United States found themaelvea short of wool and were 
forced to compete on the world lurket for needed quantitlea to 
clothe and equip our armed forces. In 1934, Congress declared 
wool an essential and strategic coonodityr^ With grcwing nld-eaatem 
tenslona, we aubmlt that the wool industry should be atljulsted 
and encouraged to expand the dooieatlc supply In the Interest of 
national defenae. We are not here to plead poverty or peraecutlon. 
We are concerned because the present bias of the Aniaal Damage 
Control Program will do lrr«f>arable damage to our Industry, and to 

Human health is at laaue as It relates to disease transmittal 
by increasing unmanaged predator populations. Energy conservation 
is at issue. Inflation is at issue caused by a decreasing product 
base. The issue is much larger than Just idwther we shsepoen can 
s^^ect reaaomablc support to protect our sheep as stipulated In 
lawa of our country. 

Will wa b« allowed to protect our private property from a 
public entityl The Issue is coaqilax. Our concerns are sincere — 
our dlsappolntnents are Justified. We urge the passage of H.R. 6725. 



D,g,tze:Jb.GOOg[e 



Shc«p «nd Coit« . 

O.S. Depirtmant of Agclcultura Crop Raporclog Boird. Bconoalcs, 



4. Sheep «nJ Goati 

D.S. Department 
Stactfttcs and 

5. Sheep and Coaci .. 

D.S. Departmenc of Agriculture Crop Reporting Board, Econoaica, 
Statlatlc* and Cooperative Service. January 25, 1910. 

6. Terrill, Clair E. 

1980. 't-redacor Loases In 32 Indivi d ual States ShowlnK 

^l^nfCIcan't L~o7ae~to Predators Since 1956 ". Report 
to Third Syoposlun on test Methods for Vertebra te 
Pest Control and Management Materials by American 
Society for Teatlng Materials, March 7, I9S0. 

7. Terrill, Clair E. 



" to Third Syafioslum on Test NeChoda for Vertebrate 
Pest Control and Management Materials by American 
Society for Testing HaCerlala, March 7, 19S0. 



Terrill, Clair E. 



"Predator Losses In 32 Individual States Showinn 
SlRniflcant Losses to Predators Since I95B ". EeporC 
to Third Synposium on Test Methods for Vertebra te 
Peat Control snd Management Materials by American 
Society for Teatlng Haterlala, March 7, 1980. 



9. Anerlcan Sheep Induatry HlKhllghta . 
1979. 



D,g,tze:Jb.GOOg[e 



Retail Fr-cwtta CmnuBPtlOD of R»d Mf t Cut* . 

1980. Natloful Uvettock & Hait Board. 

Selyn Enser, Richard Drobnick and Steven Alter. 

World Food Dewanda: The Nent 20 Ycara . 
(October 1978. The Futuriat . 

AgTlculture,.Key 2. 9; C.J.S. Agrlcultuxe 6,30 et seq. , 
Chapter 17, ' 426. 

Transcript of Bearing before the Houae Coomltcee on Merchant 
Harlne & Flaherlea, Sub-coraolctee of Flaherlea, midlife 
Conaervatlon & the Environment. 



Transcript of Hearing before the Houae Conmittee on Merchant 
Marine & Fisheries, Sub-comitttee of Flaherlea, Wildlife 
iration & Che Envlroniaent . 



March 6, 

p -, ,_hn P. Rogt__, _„ _. __ 

Wildlife Service, O.S. Departnent of Interior. 

, President, National Wool 

iO. 
_ , .... , Isslatant Secretary for 

Wildlife and Farka, D.S. Department of Interior. 

Letter to Marvin Cronberg, President, Hational Wool Grofers 
Aasoclatlon, March 20, 1980. 

Signed by Robert Herbat, Assistant Secretary for Fish and 
Wildlife and Parks. U.S. Department of Interior. 

Tarrlll, Claic E. 

1980. "Predator Losaes In 32 individual Statea Showing 

Significant Losaea to Predatora Since 1958". Report 
to Third Sympoaliun on Test Methods for Vertebrate 
Pest Control and Hanageiaent Materials by American 
Society for Testing Materials, March 7. 19S0. 



20. The Hational Wool Act of 195* . Title VII of the Agricultural 
Act of L^M (ea extended) Public Law 690, Page 17. 
The national Wool Growe r. November 1954. 



db.Google 



126 

Mr, Wamplbb. Mr. Noh, I want to thank you for your very com- 
prehensive statement. I think the National Wool Growers has long 
been recognized as, not only a prestigious oi^amzation, but one that 
by and lai^e does speak for the entire industry throughout our 
country. 

On page six of your prepared statement, you said "interior." I am 
sure you are referring to the Department of the Interior. You said 
it is "hiding behind the shroud of influence of persons who have little 
understandmg of the scope of the predator problem and who exhibit 
a capricious attitude toward the food and fiber base of this coimtry." 

I Delieve I understand what you are sayii^. Would you care to 
elaborate on that? Maybe you did so in the summaiy of your statement. 

Mr, Noh. Well, sir, perhaps an example is the best way to express 
it, without getting into personalities. 

Our industry faced a situation, when the Andnis new policy was 
presented, wherein the special assistant to Secretary Andrus was, in 
writing, listed as being in charge of handling all of the flow of paper 
work and implementing the decision, in effect. I first met her way 
back in 1972 at one of these hearings. At that time she was a paid 
staff person for one of the environmental oi^anizations which is very 
much opposed to the sheep industry on this question. 

We do not argue with objective, factually oriented people in these 
situations, but talk about putting the fox in charge of the chicken 
coop. That is exactly the situation that we have. 

We would expect under those conditions that under a new adminis- 
tration the secretaiy of the National Wool Growers Association would 
be put in chaise of the animal damage control program. That would 
not be r^ht either. 

Everywhere we turn we find these sorts of people, who do not have 
practical experience, but by philosophical bent are opposed to con- 
trolling the wildlife resource and consequently the result is the destruc- 
tion of the agricultural resource. 

That is what I was referring to and that sort of thing. That is just 
one example of many. 

Mr. Wamplbh, I certainly would not want you to get involved in 

Eerson all ties. That was not the purpose of my question, but I think you 
andled it In such a way that you cleared up any doubt in my mind 
that might have existed. 

Let me ask you a final question. Are you convinced, on the basis of 
your experience and observation, that the losses to the sheep and goat 
mdustry from predators is well documented? Is it factual? Is it accurate? 

Mr. Noh. At this point it is as accurate as we can get. It is not an 
easy thing to measure simply because of the vast distances involved, 
the complexities you run into when you deal with living things. 

The U.S. Department of Agriculture has done some good studies. 
Dr. Clair Terrill presented a paper, which is referred to in our state- 
ment, in March o! 1980. He is a good scientist. I have not had a chance 
to dig into his paper to really give it an evaluation, but I know he is 
a good scientist that does good work. 

In my mind, yes. When we started on this problem in 1972 or 1973 
the public generally did not believe coyotes killed sheep. In that 
regard, I guess we have come a long way, although some organizations 
are still trying to raise money and are convincing their constituents 



D,g,tze:Jb.GOOg[e 



127 

that coyotes do not kill sheep. However, we know they do and I think 
we have a pretty fair handle on the severity of the problem. 

Your scientific witnesses tomorrow can speak to that, I think, 
perhaps better than I can. 

Mr. Wampler. Thank you again for your statement. 

Mr. DE LA Garza. You mentioned the fact that your organization 
supported or would support transfer of the animal damage control 
program to USDA, Is that correct? 

Mr. NoH. Yes, sir. That is correct. We would. We have not felt that 
way before. 

Mr. nB LA Garza. I have been informed that USDA would not be 
adverse to accepting that responsibility. After we get through with 
this legislation it may be something that we would want to look into, 
Mr, Wampler, 

Hopefully, we will proceed and have a meeting of the minds on this 
legislation to try to help the industry and then we will come back and 
see about doing something about a transfer. 

We thank you very mudi for your testimony here, sir. 

We have one more witness. However, the House is in session and 
we have a recorded vote. 

Mr. Gillmor, if you will bear with us, Mr. Wampler and I will go 
and record our presence and will come right back and finish. With that, 
we will stand in recess for a few minutes. 

[Recess taken.] 

Mr. DE la Garza. The subcommittee will be in order. 

The next witness is Mr. Stephen Gillmor of the Utah-Idaho Farmers 
Union. I see you will be accompanied by Mr. Bob Mullins. We are 
happy to have you here, sir. We will be happy to hear from you at this 
time. 

STATEUEirC OS BOBEST J. HULLINS, ASSISTAITT SIKECTOB, 
LEGISLATIVE SEEVICES, NATIONAL FASHERS UNIOS 

Mr. Mdllins. Thank you, Mr. Chairman. 

I am Robert Mullins, the assistant director of legislative services 
for the National Farmers Union. 

I would just like to have my statement entered into the record in 
full and allow Mr. Stephen GUlmor, a member of the National Farmers 
Union from Utah, who also serves as treasurer of the National Wool 
Growers Association and is a sheep farmer from Utah, to present our 
position to the committee. 

Mr. DE la Garza. Without objection, your statement will appear 
in the record at this point, Mr. Mullins. 

[The prepared statement of Mr, Mullins follows :] 

Statement c 

Mr, Chairman and Members of the Subcommittee: I am Robert J. Mullins, 
Assist&nt Director of Legislative Services, National Farmers Union, 1012 Four- 
teentb Street, N.W., Washington, D, C. National Farmers Union is a general 
farm organization representing some 300,000 farm and ranch families. On behalf 
of the livestock producer-members of the Farmers Union, and particularly our 
Bheep producers, I appear before this Subcommittee in support of H.R. 6725, the 
"Animal Damage Control Act of 1980," introduced by the distinguished Chairman 
and Mr, LoefHer of Texas. 



D,g,tze:Jb.GOOg[e 



128 

Conaprvfttive estimatiw place the aiimial financial loss suffered by livestock 
producers due to predators at over S5D million. Looses to sheep producers from all 
predators amount to 55 percent of their total lamb loHses and 31 percent of adult 
sheep losMs. Eleven percent of calf Ioh-scs in the United States is attributable to 
predators with almost 14 percent of the calf losses in the Western states caused by 
I>redators. The losses sustained by livestock producers from predators cauw 
significant econom'c damage. 

RecognizinR the severity of the problem, and the inadequate and often counter- 
productive federal predator control policies, the delegates to the recent National 
Farmers Union convention held in Denver, Colorado, March 2-S, 1980, adopted 
the following statement on Predator Control: 

Since the 1931 Animal Damage Control Act mandates that the federal govern- 
ment shall protect the livestock industry from predatory loss, we urge that the 
Secretary of Interior reevaluate his recommendations concerning the Animal 
Damage Control (ADC) program. The proposed rules limit control measures 
available to our livestock producers and are in direct conflict with the original 
intent or the law. The Secretary's recommendations would, in effect, withdraw the 
support of the Interior Department's resources in predator control and further 
bind the hands of livestock producers in their control efforts. 

We recommend that the original intent of the law be carried out and that the 
ADC program be adequately funded and staffed to effectively deal with the 
predator problem. Stockmen are under severe financial stress because of the 
limiting regulations issued by the Interior Department. 

The coyote population is up over 300 percent in recent years and is creating 
problems to the human population. The judicious use of 1080 ani M-44 cyanide 
guns, the use of aerial shooting in winter, trapping, and other control pr..ctlce3 
must be continued on federal, state, and private lands to control coyotes, trophy 
game animals, and other predators if this country is to protect its livestock industry 
and guarantee Americans abundant food and fiber. 

We call on sportsmen to join with the livestock industry to conduct a concerted 
campaign to foree the United States Department of Interior and the EPA to act 
to restore the use of 1080 and keep other methods available for predator control. 
This action will benefit both the sportsman and the livestock industry. If an ade- 
quate ADC program is not available to farmers, we recommend that a federally 
financed indemnity program be instituted to pay for livestock losses. We further 
recognize that the Interior Department has the responsibility to control the imber 
wolf or compensate livestock producers where the timlier wolf is the predator. 

Failure of the Interior Department to commit itself to the basic goals of the 
ADC program requires that Farmers Union request the transfer of tbb vital 
program to another agency which will cany out the intent of the law. 

Mr, Chairman, if we are to have a viable livestock Industry, particularly a sheep 
industry in this country, we must provide producers an opportunity to produce 
their commodity in the most efficient manner and this includes a reasonable and 
practical approach to predator control. We believe the legislation before the Sub- 
committee today will reinstate the intent of Congress when thsy passed the original 
Animal Damage Control Act and provide producers an opportunity to overcome 
one of their most pressing and costly problems. 

Thank you. 

STATEHENT OF STEFHEN T. GILLHOB, UTAH-IDAHO 7AB1CEB8 

mnoN 

Mr. GiLLMOR. Mr. Chairman, I am pleased to be here. I am Stephen 
Gillmor. I am treasurer of the National Wool Growers Association, 
past president of the Utah Wool Growers. My statement will be made 
on behalf of the National Farmers Union from Utah. 

I have a range operation in Utah. I guess we ore the leading migra- 
tory sheep State in the Union. Our ranges run from the far west of 
Salt Lake to east of Salt Lake. It is very <liversified rugged country. 

I would like to highlight portions of my written statement and 
present it in that manner. 

Mr, DE LA Gakza. Very well, sir. Your full statement will appear in 
the record, without objection. 

Mr. Gillmor. Thank you. 



D,g,tze:Jb.GOOg[e 



129 

The National Fanners Union supports your bill, H.R, 6725, and we 
congratulate you on its contents because it parallels National Farmers 
Union policy, calling for an effective damage control program with 
adequate funding and staffing to cany out the original intent of the 
law. 

The economic situation which exists in agriculture today presents a 
fine line between a profit and a loss. In Utah we have hatf so many 
operators go out of business that it seems to be more loss than it is 
profit. 

We, in the livestock industry, face about the same 20-percent infla- 
tion rate that each American faces. We are confronted with the same 
spiraling ene^y costs, and when we go to lending institutions for 
operating capital, we too are confronted with high interest rates. 

,\s of March 15 the farm parity ratio has declined to just 63 percent 
with wool prices at 50 percent of parity, lamb prices at 74 percent, and 
cattle prices at 81 percent. 

Secretary Andrus, in his policy, has emphasized that preventative 
control should only be exercised for unacceptably high levels of loss 
which have been documented during the preceding 12 months. It 
seems to us that any loss should be deemed unacceptable if it is within 
our power to prevent. 

Recent USDA studies have reported a predator loss to Utah sheep 
and lamb producers in an excess of 16 percent in 1978, 18 percent in 
1979, and greater losses predicted for this year, I can attest to the 
accuracy of their figures. 

We live in a penod of increasing costs of livii^, I cannot think that 
any American would want to take 18 percent right off the top and call 
it an acceptable loss from his income. 

The Secretary proposes forming working groups and advisory com- 
mittees with very limited industry representation, totally neglecting 
representation from the States affected by predator problems. This 
type of disrespect for the ability of industry and regional representa- 
tion by our Government officials fuels the iires of incidents like the 
"Sage Brush Rebellion" and the American Agriculture Movement. 

I would like to point out that stockmen are environmentalists in 
the purest sense of the word. We must rely on the ability of the 
rangelands to produce forage for our stock each vear. 

It must be recognized that the rangelands of the West are a renew- 
able resource which cannot be used effectively without domestic live- 
stock. In our own situation in the nigged mountains I cannot pull 
sheep camps, so I have to use mules to pack. There is a fine crop of 
grouse and grass and weeds and forage that grow in this country and 
there is only one way to harvest that crop. That is with sheep. 

In some areas similar to it, I suppose sheep and goats would be 
appreciated. 

Some wildlife biologists have found that coyotes and other predators 
adversely affect the reproduction of large game animals, like the deer. 
An effective predator control program will lessen the predation prob- 
lem on our wildlife population. 

We, in Utah, had a program with our hunting people. We tried to 
ally them with us. We did manage to get over a great understanding 
of predation on the deer population. We aroused them by coming out 
with a bumper sticker: "Did the coyotes kill your deer?" 



D,g,tze:Jb.GOOg[e 



130 

In 1977, when President Carter t^ave his environmental message to 
Congress, a much more imposing problem surfaced, the energy cri^. 
With this effort, Americans will oe usin" less synthetic fiber, hope- 
fully, and returning more to the natural nbers, wool, and cotton. 

We need to look to the renewable resources of a rangeland to 
produce both food and fiber ut a minimal expenditure of energy. 

Farmers Union recommends the judicious use of 1080, the M-44 
cyanide gun, the use of aerial gunning in the winter, trapping, denning, 
and other control practices on Federal, State, and private land to 
guarantee a viable livestock industry producing an abundance of food 
and fiber. 

Use of the 1080 toxic collar appears to fulfill the criteria set forth 
in the Secretary's policy. It is selective to the point that it removes 
the offending predator. 

The ADC program as mandated in 1931 is not a pr<^ram of extermi- 
nation of predators but is one of control. Neither the Farmers Union 
nor stockmen want to eliminate total populations of predatory 
animals. However, a control program is necessarv. 

A report by the Utah Department of Agriculture shows that the 
ADC program is conducted on onlv 1 1 percent of the Western State's 
land area, with aerial hunting ana denning practices used on only a 
small proportion of that 11 percent. 

In vtih spring lambing coincides with coyote whelping. The 
pups are not the actual predator but they are indirectly the cause of 
apparent predation on the lambing operation. I left the desert day 
before yesterday and in rounding up we found five ewes — we start 
lambing in May — in a very small area, each of whom was opened 
up by coyotes and the unborn lambs were taken from the womb. 

Aerial hunting, especially in the wintertime, with snow cover is 
another control measure which can be directed at regions of high 
predation and u'ill generally register immediate results. In our area 
we use it as a preventive program on our summer and spring ranges. 
When the snow is on the high mountain country we fiy in ana do wis 
type of work and it is most effective. 

In winter we fly over snow cover and have great effect on Uie 
the coyotes near and around the herd. 

In the absence of an effective predator program in the State of 
Utah, it is questionable whether or not sheep producers will be able 
to withstand the economic losses from predation. 

Bob Reynolds, who heads up our fisn and wildlife animal damage 
control in Utah, when Andrus' report came out, said, "Well, I give 
the industry another 3 years." 

The Secretary's policy regarding livestock husbandry techniques to 
reduce conflicts between livestock and predators seems to be out of 
place. In recent years our predator losses have dictated that herders 
keep the stock closer together for protection, but best range manage- 
ment is to spread out tne herd so the range is not oveigrazed and 
damaged. 

It is quite a dilemma when Forest Service and BLM directs us not 
to bed our herds more than two nights in any one spot and yet tiie 
Secretary comes out and tells us that we are going to have to have 
tight herding practices in order to reduce coyote predatitm. 



D,g,tze:Jb.GOOg[e 



131 

National Farmers Union policy calls for an animal damage control 
program vnth adequate funding and staffing to provide the necessary 
protection to livestock producers. If an ADC program of this caliber 
IS not available, then a federally financed indenmity prc^am should 
be instituted to pay for the livestock lost. 

The Secretary's policy statement is a clear failure by the Department 
of the Interior to commit itself to the original intent of the law and is 
considered unacceptable for the continuation of a viable livestock 
industry. 

In conclusion, I would like to say that we, in the sheep business, 
have produced optimum yields of meat and wool when we had a full 
spectrum of working tools to handle this situation. When we had all 
the methods of predator control at our disposal, we were raising tai^ 
percentages of lambs with much less cost. 

We were able to produce these things without askir^ for subsidies, 
without asking for nandouts from anyone. We were able to make a 
good business out of the sheep industry. At this point, it is impossible. 
Coyotes are not an endai^red species. When our heavy control 
program was taken out of effect the coyote population flourished and 
IS now 300 percent of the level at that time. 

I think that if we can be given a suitable predator control pr<^am, 
we will produce great yields of food and fiber for our Nation and the 
world in these cntical times. 

I thank you for being able to make this presentation. 
Mr. DB LA Garza. Tnank you, sir. 
Mr. Wampler? 

Mr. Wampler. Mr. Gillmor, I just want to compliment you on 
your very comprehensive statement. I think you emphasize some of 
Uie points to which earlier witnesses have testified. 

I will ask you the same ouestion that I have asked several of the 
other witnesses. That is, do you feel that the losses to the livestock 
industry that result from predators is well and accurately documented? 
Mr. Gillmor. I do, Mr. Wampler, 

It is a difficult thing, with ranges such as I have that are very 
brushy and rugged. You learn by experience what percentage of loss 
might occur. 

If you are on an open plain it would be possible to some extent to 
count most of the deaths, but in the rough brushy areas such as we 
are in you have to rely on what you have seen m the past and on 
your computation of tne counts on and the counts off, never being 
able to recover the stray loss. In view of that, I think they are well 
documented. 

Mr. Wampler. In any event, it would be fair to say that the loss is 
substantial and significant. Is that not so? 

Mr. Gillmor. Yes, In Utah in 1972 we hod 1.2 million sheep. At 
the present time we have about 565,000 ewes, so you can see what has 
happened in 8 short years to the Utah sheep population. 

Mr. Wampler, I will also ask you the question that I have asked 
other witnesses. One of the recommendations of Mr. Andrus was that 
we go back to having herdsmen to go with the flocks. Would this be 
practical in your area of Utah and ike other areas that you represent 
today? 



D,g,tze:Jb.GOOg[e 



132 

Mr. GiLLMOR. In my own particular operation I do use herders. I 
use herders all the time except in the shed lambing part of my operar 
iion. Those men work in the shed. We have used all of the practices. 

I grew up in a situation where there were predators. When we came 
to bedding grounds, we tried everything. We nave tried extra bells. We 
have tried bedding sheep with radios playing on peaks. Some of the 
thmgs work for a short time. 

We have tried firecrackers. The coyote is a most intelligent animal. 
Once they see your pattern and know what it is, and they get used to it, 
it does not matter what you do. They will come in anamake a kill. 

Mr. Wamplbr. You also indicated tnat it was your opinion that the 
coyote is not a potential candidate for the endangered species list. You 
might have heard the response of one of the witnesses from the En- 
vironmental Protection Agency this morning when he replied to a ques- 
tion. He said that perhaps the coyote will be a candidate for their list 
of pests. 

I quite a^ree with you. I can distinguish in my own mind betwe^i 
predators ifke the eagle that is on the endangered species list and the 
coyote but, again, the question is: How do you weigh legitimate 
environmental concerns against those of sound economics and prae- 
ticality? That is what this i^ubcommittee is attempting to do, of that 
I want to assure you. 

Thank you very much. 

Mr. GiLLluoR. Thank you, Mr. Wampler. 

Mr. Chairman, may I submit a statement from Dr. Creer, our secre- 
tary of agriculture in Utah? He asked me if I could deliver it to this 
committee. 

Mr. DE LA Garza. Yes, sir. Without objection, your entire statement 
and the statement of Mr. Creer will be made part of the record at this 
point. 

[The statement of Stephen T. Gillmor and Kenneth B. Creer 
follow:] 



D,g,tze:Jb.GOOg[e 



STATEMENT OF 



I (m SCapliao. T. GlLImoc, & mafflbar o£ eh* Haeion ramara Driion 
££oa Oeah, eraaaurar of tha HaUonal Hoot Orowars Aasociation. past 
praal,4aat. o£ tba QCali Wool Srovara and a ahaap producac. t appraelaCi 
tha oppcrtUDlCY- eo offar this ■eaCamaBC eODcacnln? tha Animal Danaca 
Control peogram oo bahalf of tha 300,000 oanbar fsm eamlliai at tha . 
National Facraara Dnion. 

Tha HatlacaX TAcmmc* Onioa aupporta U.K. 5735, Introduead by 
CoQ^raasman da la Sana and Coc^raaamaii Loafflar. baeauaa it pacallali 
National Famara UbIoo policy calling for an affactlva Animal Damaga 
Caatral prolan with adaquata funding and a-tafflng to carry out tha 
ociglnal Intant of tha law. 

It 1> elaarly avldant that tha Sacratary of Intaclor'i Hnvambec > 
8, 1979 poller announcaaanC cagarding tha ADC program raflocta tha 
pcaaaura axartad by anvironmaiital groups, falling to coaaidar tha 
far raachlng isqpaet It will hava on tha wastern liveatack industry. 
This daeiiioD la in diraet conflict with cha original intant of tha 
1931 Congraasional nacdata which diracta tba Intarlor Dapartoaot to 
davalop and nalntaln ma af f aetlva. pradator control program to pro- 
tact this nation 'a llvastock raaource from pcadatory loss. Tha ACC 
program affactivaly controllad loss from pcadators until 1972 whan 
Peaaldanc Klxoo banoad th« uaa of Compound lOSO-govamnantal ra- 
DDval of a workable tooL. 

Tha aconomlc situation, which axlsts in agricultura today praaants 
a flna line batwean a profit and a loaa. He in tha llvastoc!c industry 
Eaea tha sama 20 parcant inflation rata that each Amarican facaa; wa 
ara confronted with tha same aplrallng energy coats: and when wa go to 
landing Institutions far operating capltol. wa too ara confrontad 
with 20 parcant Interest figurai. As of March ISth. the farm parity 
ratio haa declined to JuaU 63 percent ot parity with wool prices 
at SO parcant. lamb prices at 74 parcant and cattle prices at 81 
percent. At the lame time governmant acononiata ara predicting a 
ZS to 30 percent daeliDB in gross farm incase In 1980. The parity 
formula maasures the purehaalng power of farm and ranch commodities 
Id respect to articles purchaaed by farmers and ranchara using tha 
years 1910 to 1914 for a base to datamine prices for both agricul- 
tural and non-agricultural eomnoditles. 

secretary Andnia, In his policy has empbasiied that preventative 
control should only be exercised where unacceptably high levels of 



D,g,tze:Jb.GOOg[e 



Loas hava baan docuMuiead during tha praeadiag 12 Bootba. It laaiu 
th*E uif loaa aliould b« daaaad •■ ixiau.«|<.rijla if it la witbin our 

flacant nsDA •Cudlai hava raportad a pradatorr loaa to Utah ahaap 
and lamb producara In axcaaa of 16 paccant during 197t. IS parcant 
during 1979 and graatar Isaaaa pradlctad far 19S0. Ha llva In a 
parlod of Incraaaing coata -of- living; would sthar Amarlcan Induatrlaa 
or avao tha waga aamar find It accapeabla to taka away IS parcant 
of Ita groai loeotaa for aor raaaool Tha Intarlor Dapartmant with 
Ita raaaarch budgat has fallad to provlda any guldallnaa for lavala 
of loaaa* which are biologically de aven loclally 'accaptabla'. 

Stocloiian ara confronted by different predatory problaiu ae wa 
Dave from one region to another and froa ona aaaaon to tha naxt. 
The Secretary propaeee faming working groupa and advlaory eooaltteaa 
with very llaltad industry rapraaantatlon and totally neglecting 
rapraaantatlOQ froa tha atataa affected by predator problems. This 
type of dliraapaet for tha ability of induatry and regional rapce- 
aentatlon by ouc goversBent officials fuel tha flraa of Ineldanta 
ilka tha 'Sagabrush Rsballlon' and tha AinarlcBn Agriculture Move- 

At the National Famers Union annual convention held In Harch, 
our delegates raafflmad our cooalttmaat to tha original Intent of 
the 1931 Anlnal Daoaga Control Act and raeomaenda that the Secretary 
□f the Interior should ca-avaluata hla policy of withdrawing the 
Interior Dapartmant 'a lupport la affective predator control and 
further binding the handa of livestock producer! In their own con- 
trol efforts. This Is particularly davaatatlng In tha Mountain 
west where In Otah S« parcant of tha land la controlled by tha 
Bureau of Land Nanagaeiant, Forest Service and State Lands. Many, 
of tha waatam states find thamaalvea In almllar altuatlons. 

stoekaian ara anvlronnsntalists in tha puraat aansa of the word. 
Ha must rely on tha ability of tha range lands to produce forage for 
our etock each year. It oust be recognized that tha range lands of 



tha wast are a renewable 
Without donestic livesto< 
brush'' f the primary diet 
compata with grass. Llvi 
the ranawabla mountain gri 
additional wildlife foragi 
Farmer* Dnlon ha 



lourca which cannot be used affidantly 

Range biologists have found that "blttar 
' deer populationa in tha west, cannot 
ick grazing, properly managad, utllliea 
laj and makes room for the growth of 



on sportsmen to aid in the campaign 
'ce tha Interior Department to conduct a viable Animal Damage 
il program and keep control nathoda available to stockmen. A 



D,B,i..ab,Google 



coup* CO hav* ti««lthr tflldlifa 



naatJ 



' of Cjivef M^naa 



COmpl.8C 



scudie 



impact of th* WC program od domHtl 
•how«d that ovac half ot tha itudy' 
program la bflncficlal ta both Llveai 

■dvaricly Bf£«cc tha EapcoductloD ol 

tlva pcadator control program will 1< 
«or -iflldllfo populaclona. 

ID loutlivaat Dtah. 1b an acaa callad tha Baavar Dam SXopa. blolo- 
glata ara studying the doaen 



xlldllte. 



spaelaa includ- 
.heep A affac- 



■aan tha pradatlon 



n vast! gallon 



It s 






1 affaetlva predator control pro- 



Sloce 1977, wban Praaldant Cartar made hi* Envlrounantal Heaaagc 
3 Congraa*. a much iDore Impoalng problem haa surfacad, tha anargy 

rials Our Praaldant haa tegun a concentrated conservation program 
dcfrease our nation's dependence on Impacted oil. Ma hava alt 



:ooply 
argy cc 



affoi 



'ill b 



and will ba returning to nai 
varm. Sine* 1974, the yaar 
• ap br £0 

d {laiolina 



tlon o 






; fiber from oil 
■uch aa wool, to kaap tham 
t oil shortage, the fonsiuip- 
I para- 






Parmecs Ijntoo del agate a r< 
that llvsBCDck producers i£6 
policy will add further financial burden on the agricultural sectoi 
Since tha ban of 080 the coyote population has bo«a Ineraaalng. 
eaueing additional llveatocX loss aod creating human health 
problema through disease they carry such 4s labiea Our policy 
oppoaed the initial ban and the Secretary's prohibition of further 
raseacch and developnient of potential use for 1080 Farmers Union 
raco^wDda -the Judicious use o£ lOSO and K-** cyanide guns the 
use of aerial gunning in winter, trapping, denning and other centre 
practical of fadaral. ataca and private land to guarantee 4, viable 
liyeatoek Industry producing an abundance of food and fiber. 



D,g,tze:Jb.GOOg[e 



Tb« profaibltien of raaaareh and davalopnuit of tha uaa of 
compound loao saaiu topaaaaaa puraly political ^tlvaa alnca ra- 
^■atch Id racant yaaca haa davalop«d loathoda ot uaa whLch can ba 
•afa (ad «alactlva ulthouc known aacendarY effaces vhlla provldiaQ 
an affaclaot csDtxol maehod to raduea livaitock loss. Uaa of tM 
108O toxic collar appatfs to (UlftlX the crltarla aat forth in tha 
Secrecary s policy It la aalactln to tha point It cBBOvaa only 

Th* ADC program aa nandatad In 1931, la not a program of axtaxmlaa- 



nor atoctanon want to alimlnata total populations Of pradatory 
animals liowaver, a control program 1» nacaiaary. A raport by tha 
Utah Department of Agriculture Ahcmt that tha ASC program la conductad 
on only 11 parcant of the veatarc atataa land araa, with aarlal 
hunting and daoolng practices used Od a aD«ll portion of that 11 
parcant. In Utah spring lainbliig colDcldes with coyote wbalplBQ. 
Iha pupa ara not tha actual predator but thay Indlractly ara th* 
cause of th* parant pradatlon on lambing oparatlona. At th* aaaw ttaa, 
tha pacsnt coyotes aee training the aaKt ganaratioa of ahaap pra- 
datora. The tool of jflnnlng is an economically afflclent and aalae- r 
tlve practice aimed at the offending coyots and Is oftan th* only 
method which can atop killing when adult* cannot be removed. A*rial 
hunting la another control measurB which can be directed at raglona 
of high pcedation and generally will raglatec immediate results 
Without th* uaa of Choaa practleaa, wa will have to turn Bora to 
th* ua* of traps and M-«4 cyanide guns not as humane rtor naarly aa , 
a*l*etlv*. '*^S. absence of an affective predator program in the Stat* 
of Utah, it is <iuestlooable whether or not llveatocX producers will 

Tha Secretary's policy regarding livastaek husbandry tachniquaa 
to reduce conflicts botwaen livestock and predators seams to ha cut 
of plaea. It la not ona of the responaibilltias of thla program. 
hoMavar. many of the cacommendationa are Ineffactlwo in tha Mountain 
States far rang* operators He hiva always uaad herding on opan 
rangas to keep -Our stock within the allotments and moving to n«w 
grailng. Id racent years, our predatory loaaea have dictated that 
hardara heap th* stock cloaer together for protection, but b«st 
rittgt irianagement la to spread out the herd so tha rang* la not ovar 
grazed and damaged Th* altamativa of fencing la not feaaibla in 
a state where government control* S£ pareaot of tha land araa. Tha 
land areas requiring fanclng ac* uo l*m* to naka It an aconoBieal 
investsiant and It would not altar tha pradatoc problem. 



D,B,i..ab,Google 



'The ADC policy umouncemsnt by Secretary Andrul is indicative 
of the fnistntloD that llvaitock produeara ar* confronted with trom 
HaahlDgtoo. D.C- ia raeaot yaacs. Bii Bsnouscemeiit uai raported aa 
compcomisea betwaan both atocloMB and aDvlrotuBantallat* . The com- 
promlaaa nana- the- lei a, seem to drsaClcally favoc the envlronniantaliits' 
poattloa without aoclal or biological raaion. 

National Tanaaea onion policy calla for an Juilnal Damage Control 
program with adaqoata funding and staffing to provide the necessary 
protection to livestock producers. If an ADC program of this caliber 
la not avallabla. than a fedarally financed indemnity program should 
be Instituted Co pay for llvaatock loss, with the increasing demand 
for red meat and vool, an Indemnity program allowing loss of both 
is contrary to the need of peoduelag food and fiber for human use. 
Fanaars Union policy further recoimends that where a protected species 
la cauaing the predation problems, such as the timber wolf, stock- 
man should bs eoovaoaated. 

The Secretary's policy statement is a clear failure by the 
Interior Department to comnlt Itaalf Co the original intent of 
the law and is conaldarad unacceptable for eha oentinuatlon of a 
viable livastoek Industry. The national Farmers Union is seeking 
to reinstate an aeeapfeable predator control progran to ashleva this 

Ha In the shaap industry hava produced optimum yields of meat 
and wool, whas wa had a full spectrum of "working tools" to effectively 
control pradatlon. As these tools have bean removed, beginning in 
1973. our shaap losses have been tremendous. Our sheep numbers hava 
bean continually declining, until 1979 whan the trend wa* ravaraed 
and reported a 2 percent increase. 

Coyotes are not an endangered spaelas. Hiicory has proven chair 
adaptablllcy and ability to survive. Give us a suitable predator 
control program and wa will produce great yields of food and fiber 
for our- nation and the world. 

Thank you. 



D,B,i..ab,Google 



Pbkpared Statzuemt of Dit. Kenneth B. Crees, ComcnaioxES, Utah Statb 
Department of Aqriccltcre 

Mr, Chairman and Committee Members: The Ut&h Department of Agrieulture 
ftpplsuda vour concern with Animal Damage ControL We support HR ft72S 
introduced by Congressmen de la Garza and Loeffler. 

We are concerned with Secretary Andrus and the Department of Interior 
policy on the ADC Program issued November S, 1979, which completely ignores 
testimony from an industry that supports a strong tax base and is a vital part to 
the economic structure of tne Westem United States. 

The evidence is strongly evident that the Secretary yielded to the political 

Eressure exerted by CEQ with complete disregard for the ADC Program mandated 
y law in 1931 and testimony presented by the livestock industry at hearings in the 
regional EIS hearings. 

Predator damage in the Western United States causes serious economic losses 
to the rural areas of the West. The renewable resources of grazing public lands 
should receive appropriate priority in the multiple use concept. In many instojices 
the Secretary's policy lacks objectivity and is not based on established fact or 
competent professional ai)praisal. 

The Policy bans "denning" as a barbaric tool of ADC Program; when In reality, 
it is an inexpensive method of control. Those opposed to this tool on humane 
ethics should view mutilated lambs and their distraught mothers after coyote 
attacks. 

The Policy requires extensive documentation of losses before corrective control 
may be initiated. It eliminates the use of proven methods in favor of unproven 
non-lethal method focused on the individual offending predator. 

At a time when research with the toxic collar and compound 1080 ia proven 
effective on offending predators, all research on this highly selective toxicant is to 
cease. The livestock industry was implicitly given assurances that development 
research, on the toxic collar would lead to registration if certain criteria were met. 
Now on the threshold of practical application after many years of research it is 
prohibited by the USDI. 

Traditionally the ADC Program has been a cooperative effort with federal, 
state, and private land management personnel. We are concerned that the USD! 
Policy Statement will terminate cooperative programs in favor of individual 
private control efforts, which will result in the indiscriminate use of methods which 
are not controllable; therefore, defeating the very purpose of the Policy. 

We recommend the Policy be abandoned in favor of an objective pn^ram of 
predator control and not extinction, a program compatible with all facets of 
concern. This will require a balanced committee of professional, knowledgeable 
members. 

The ADC Program is vital to our Western Citizens and urge the need for ccm- 
tinued research and use of proved control methods. We also support passage of 
HR 6725. 

Thank you. 

Mr. DB LA Garza. We thank you both for being here and for your 
testimony which I think will be quite helpful to us. 

The committee will stand adjourned until 10 tomorrow morning. 

[Whereupon, at 3:35 p.m., the subcommittee stood in recess until 
Thursday, April 17, 1980.] 



D,g,tze:Jb.GOOg[e 



ANIMAL DAMAGE CONTROL ACT OF 1980 



THOnSDAY, AFBIL 17, 1080 

House of Refbesentatites, 
Sttbcohmittee on Department 
Intestioations, Otersioht, and Research 

OF THE Committee on Aoriculturb, 

WashiTigton, D.C. 
The subcommittee met, pursuant to recess, at 10:10 a,m., in room 
1302, Longwortb House Office Building, Hon. E de la Garza (chair- 
man of the subcommittee) presiding. 

Present: Representatives Skelton and Wampler. 
Staff present : Fowler C. West, staff director; John Hogan, counsel; 
Peggy Fecore, clerk; Bernard Brenner, Bert Pena, Mario Castillo, 
Jeriy Jorgensen, and Thomas Adams. 

Mr. DE LA Garza. The subcommittee will be in order. 
This morning we continue consideration of H.R. 6725. 
The Erst witness this momingis the Honable Gus Douglass, com- 
missioner of the West Vii^inia Department of Agriculture. Is Com- 
missioner Douglass here? 

He does not seem to be so, without objection, we will receive the 
testimony of the commissioner if he appears. Otherwise, we will receive 
it for submission into the record. 
John Grandy from the Defenders of Wildlife of Washington, D.0.7 
I see that you will be accompanied by Mr. Dick Randal. We wel- 
come you and will be happy to hear your testimony at this time. 
CI39) 



D,g,tze:Jb.GOOg[e 



STATEMENT OF JOHN W 

ACCOMPABIED 1' 

OF DEFEIIDEllS, toot SFRINGS, WO. 



Mr. Chairman, ConniictM iMnbara. My nan* la John H. 
Grandyi I am Executive Vice President of Defenders of Wild- 
life, a major national niiaiife conservation organiiation. 
I an accompanied today by Mr. Richard L, Randall, North Cen- 
tral Field Representative of Defenders, based In Rock Springs, 
Hyomlng. I appreciate the opportunity to testify today on 
il.R. 6733 and H.R. 6725, bills that would drastically altar 
the predator control program which Secretary of the Interior, 
Cecil D. Andrua, approved on November B, 1979. 

I have a B.5. (1966) in Forestry and Wildlife Hanaga- 
ment from Virginia Polytechnic Institute and State Univscsity, 
and a M.S. (1968) in Wildlife Biology and a Ph.D. (1972) In 
Wildlife Ecology, both from tho Unlvoralty of HasBSchusetts 
In Amherst. I have an extensive educational and professional 
background of study and interest in the principles governing 
the workings of ecological systems. I have worked, among 
others, for the Virginia Conraisslon on Game and Inland Fish- 
eries, the U.S. Forest Service, and the n.S. Fiah and Wild- 
life Svrvlcei immediatflly before assuming my present position, 
I was chief assistant to the Senior Scientist at the Presi- 
dent's Council on Environmental Quality. In addition, I was 
appointed to. and served as a member of, the recently con- 
cluded Animal Damage Control Policy Advisory Ccmmittee to 
tha Secretary of the Interior. 

Mr. Randall has worked in Wyoning and Montana as a ahaap- 
herder and cowpuncher. Be was employed by the D.S. Fish and 
Wildlife Service as a predator control agent from 19S7-62 and 
again from 1967-73. His job titles and duties included: Gov- 
ernment trapper; district field assistant! principal dlatrlct 
field assistanti and, twice, acting supervisor for predator 
control activitiea over five southwest Wyoming counties. 



D,g,tze:Jb.GOOg[e 



"" Mr. Randall and I prapared thla •tatenient based on our 
coll«ctlve exparlsncaa and •xpartlse. Me are prsaentlng thla 
statement on behalf of Defendera of Wildlife, Environmental 
Defense Fund, International Fund for Animal Welfare, Friends 
of Wildlife, Sierra Club, Fund for Animal*, Natural Resources 
Defenas Council, Center tor Action on Endangered Species. 
National Parks and Conservation Association, Animal Protection 
Institute, Friends of the Earth, The Wildorneas Society, 
Rare Animal Relief Effort, and World wildlife Fund. 

He judge from the language of the bill and the remsrXs of 
the Chairman that the intent of H.R. 6725 (and, similarly, 
H.R. 67331 is to aid the livestock Industry. The intent of 
these bill* is commendable; indeed. Defenders strongly sup- 
ports the existence of a healthy western livestock industry 
which is responsive to the needs of this nation for food as 
well as for the proper management of and necsaaary protection 
for, respectively, public {and private) rangelands and this 
nation'* wildlife heritage. To the extent that these bills 
ore aimed at aiding in achieving such a healthy industry, 
we co^nd the goals. Tlnfortunately, the methods by which 
the bills would aid the livestock Industry are inadequate — 
and in all likelihood counterproductive — to attaining the 

However commendable the goals, the bilKa) simply will 
not solve either the specific problmna caused by locallied 
wild predator(s) or the overall and larger problem* of the 
livestock Induatry, Moreover, the bill(s) fail to make the 
necessary provisions to identify and protect the public wild- 
life heritage on the public trust lands of this nation. In 
addition, it is clear that in order to provide the induatry 
with solutions to the problem* which have been associated with 
predators and other factors, a totally new approach ia needed. 

I will discuss each of these subjects independently. 



db.Google 



The bllKil will pot ■olve althr th« ■pacific probli— 
cau— d by loe«lli«d uild pr«d«tor[>) or th« ovr«ll tani 
larg«r problaim of th« llvtock Indmtty . 

A. This bill dots not address apaelflc. localized 



GENERALIIED, HON -SELECTIVE LETHAL CONTROLS 
DO HOT WORK AMD MIU, NOT SOLVE PROBLEMS OF 
LIVESTOCK LOSS. 

The sheep Industry haa over the last thirty years bean 
the recipient of naialve wnounti of preiuDed help in th* 
fono of nearly every conceivable predator killing technlqae. 
Unfortunately, this alleged help has never solved the problMB 
of liveatock loss. Some reasons for this can only be infarredi 



The sheep industry grew to tha height of its economic 
strength many decades before the introduction of toxicants 
such as thallium sulphate and lOBO (sodium nonof luroacetate) 
and before fixed wing or rotor wing aircraft came into use 
for predator control purposes. The industry grew at ■ time 
vhen the wolf and cougar and evsn grizzly bears were still 
present in the ecosystems of the Heat. Then, predator control 
had not achieved anywhere the level of intensity it has today. 

The industry's decline began in the ISIO'a and continues 
yet today. (Testimony. Pigure I.) 

ThuB, historically, predatora have not prevented the 
sheep induatry from experiencing atrong growth, and likewiae, 
govemment-aponsored predator control programs have not t 
versed the economic declines. 

Total numbers of sheep and goats being graied on ?oi 
Service Lands have shown a steady, year-by-year decline s 
1940, paralleling the decline in nationwide numbers dlacu 
by Gee. (Teatinony, Table I.) 

Further, 'Predation loasea as a percent of total grata 
remains roughly stable in the early years, falls ahaiply d 



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ing eha first yaara of 1080, but than ratum* to its foraeE 

lavel lAlla 1030 waa atill In uaa. Tha 'total gcatad' fi^iica 
continuad its dscline throughout tha lOBO ars and bayond. 
Thus, once again, the data show that predator control, in- 
cluding deadly poisons, has not aolvad the induatry'a real 
problems. 

Other reasona why livestock loss probleaa are not aolvable 
using traditional approachaa auch aa those endorsed in these 
bills are the way in which losses occur and the extant of 
Bueh loaaaa. 

The predator problam, where it exists, concerns mostly 
sheep and goats. Cattle losaea to predatora are relatively 
Inaignif leant. A D.S. Department of Agrieultvirs aurvay of 
1,800 ranchers and farmers throughout tha nation concluded 
that predators killed less than one-tenth of one percent of 
beef cattle, 550 pounds and over. In survey populations in 
1975. The majority of these predator losses were attributed 
to other than coyotes and dogs. 

Losses of calves (less than 500 Iba.) to predators occur 
at a higher rat* than losses of cattle but are minor compared 
to losses to other causes. Reported losaea to coyotes in the 
Western states range tram 0.4 percent in the Great Plains 
region to O.B percent in the Southwest. The highest loss to 
all predators, 1.1 percent, also occura in tha Southwest. By 
coDpariaon, calf losses to theft, diseaae and other cauaea are 
subatantially higher, ranging from 3.S percent in the South- 
west to 9.1 percent in tha Great Flalaa region. 

In ahort, cattle losses are so low as to be nearly in- 
aigniticont on even a weatwide acale. And, given the low 
and apotty nature of the loaaea, a non-aelective predator 
control program aimed at alleviating such loaaea would be 
singularly futile and coat-ineffective. 

In addition, loaaea to predators are spotty and highly 
localited. The DSOA estiaated (Gee, at al. ,13T7) that tS per- 
cent of Mestem sheep ranchers suffer no ewe or lanb loss and 
67 percent of Western ranchars suffer no ewe loss, rurtberi 



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most ranchsra that do auftar loaa auffar relatively Blnor 
loaa. Thereforei tha pradator problam doaa not land Itaalf 
to aolutiona that attack an 'average problan' or to the con- 
cept of prophylactic control. 

Theae bllla neither acknowledge the localized nature of 
tosses to predators nor do they provide any means or guidance 
with which to deal with aueh local problenu, ahort of 'balance 
between lethal and non-lethal controls* (see page 13). 

Furthermore, reported losses of liveatock to predators 
are highly exaggerated. For example, the aitea used by rish 
and Wildlife to study predator control/liveatock loss were 
not randomly selected. In fact, aome of the study sites, such 
aa the Cook Ranch (Benne, 19751 were aelected or allowed to be 
used specif ically because of high annual reported loss rates. 

To compound the error, results from study sites that were 
anything but randomly selected were then assumed to be typical 
of losses westwide, even though nearly one-half of ranchers 
are known to suffer no losses. (See attached letters to 
Hr. Steven Freudenthal and Dr. Eugene Hester from John H. 

Further, the built-in bias from mail surveys that re- 
port very high loss rates begin to unravel when follow-up, 
detailed ground aurvcys are conducted. 

For instance, on page 26. 'Predator Damage in the West', 
a nationwide mail survey estimated that lossea in California 
were 2.7 percent of the ewes and 9.7 percent of the lambs 
killed by predators in 1974. A comprehenaive survey by Hesse 
et al. 11976) in the same year in California, however, showed 
only I.l percent of the ewes and 2.7 percent of the lambs to 
have been killed by predators. Furthermore, the same D3DA 
nationwide nail survey shows, in Kansas in 1974, that 3.2 per- 
cent of the lambs and 3.4 percent of the ewes were lost to 
coyotes. A Kansas study by Meduna (1975-76) in which loaaea 
were verified and 25 percent of ranchers were contacted, shows 
only 0.7 percent of the ewes and 0.9 percent of the lamba as 



D,g,tze:Jb.GOOg[e 



being lost to coyota*. On this basis, IG SMm* highly likely 
that the nSDA sorvay pcoduced axecssiva, blassd mortality esti- 
mates, perhaps based on the expectation that a sbowing of "high 
mortality* would being increased federal aid. 

In sum, for the sheep and goat Industry, we knotf, based 
on the bleses Inherent In Bathod of survey and/or .celeulation, 
that loss levels *oa the sverage' ara probably substantially 
below the 'axaggarsCed* levels estimated by either tha U.S. 
Departntant of Agriculture or the Fish and Nildlifa Service- 
To the extent that these bills would provide 'adequate' non- 
selective lethal controls to attack this exaggerated problem, 
major unnecessary destruction of wildlife can only result- 
Further, since the distribution Of real losses Is admittedly 
highly localized, such Bass non-selective destruction would 
probably not help Individual ranchers except by accident any- 
way. In ahorti the only chance that lethal controls can be 
effective is if they are directed at verified losses in par- 
ticular areas, a concept that these bills fall to acknowledge. 

A final reason why the generallied, DOn-seleCtive lethal 
controls provided by these bills will not work Is that not 
all coyotes est sheep. For example, in pen experiment*, 
Connolly et al. (1976) found that 3 of 11 coyotes reared in 
captivity did not kill aheep. At Logon, Utah, FHS biologists 
had IS of 19 pen-raised coyotes kill sheep but found that only 
38 of 54 uild-caught adult coyotes killed sheep when placed In 
a one-hectare pen with them. The remainder did not kill sheep 
even though food was withheld for several days. Further, 
BeasoD and Gober (1975) observed high levels of coyote activity 
In pastures where no livestock losses were reported. In one 
instance in Texas about 500 coyotes ware trapped from the same 
pasture where only 13 of nearly 700 goats turned up ndsslng. 



D,B,i..ab,Google 



In ahorG, avan in Choae araaa triiar* localliad los*«a ara 
raportad, al). coyotaa nay not ba aaauoail to ba llveatock 
killacs. Hon-a«lactiv« tachniquas which kill non -of fending 
coyotea are likely to be counterproductive Co livaatock aa 
wall aa the Innocent coyote, aioea a liveatock-eating coyote 
may ultimately replace the oistakenly killed anlnal. Again, 
the billa do not acknowledge the need to provide for a way 
to direct lethal controls at offending aninala. 

THE BILLS GIVE NEARLY HO ATTENTIOH TO 
ANIMAL HUSBAHDRY TECHNIOOES ABD OTHER 
BON-LETHAL CONTROLS THAT SHOW CONCRETE 
POSITIVE RESULTS. 

Such tachniguea include efficient herders and aonatljnea 
night herding; ahed lanbing: night corralling; guard doga (aee 
attached taatlinony) ; fencing, eapacially farm flocks; and taata 
avaralves such aa lithium chloride. The latter, highly prcniaiog 
technique ia uaed operationally in the Canadian province of 
Saskatchewan, and haa been uaad aocceaafully in field experi- 
ments in the United States. 

All of these tools are aimed at preventing lossaa and 
protecting aheep, which ahould be the name of the game, rathar 
than killing coyotes. 

The application of iion-lethal depredation controls would 
allow coyote populationa to reach more stable lavela,. persiat 
at lower productivity with smaller litter aize, have a smaller 
annual turnover in their population, and a larger proportion 
of older individual!. This would maximita the effactiveoaaa 
of tachniques such aa taste aversion that depends on learned 
behavior and eliminate the costly. Inefficient anarqy-inten- 
sive programs necassary for constant ineffective population 
reduction. 

Unfortunately, tha bills in question hardly provide tor 
non-lethal controla except to suggest that a balance betwaan 
lethal and non-lethal controls should exist, and tha 'balance* 
la never defined. 



D,g,tze:Jb.GOOg[e 



Regardleaa, howavar, ehara ii no nead for thla 'balance*, 
whatever ita definition. If non-lethal controla can reduce 
loaaaa to acceptable lavela. Clearly, no one should want to 
kill th« public's coyotea Go atop predator loiiaa it thaae 
losaea can be stopped through other non-lethal Beans. 



THE BILLS DO HOT PROVIDE OR EVEN ATTEHPT 
TO PROVIDE PUBLICLY ACCEPTABLE FORMS OF 
CONTROLLING EVEN LOCAL LIVESTOCK LOSSES. 

A recent national public opinion survey conducted by 
Gallup for the U.S. Fish and Hildlifa Service and Yale Uni- 
versity Makes clear both the overwhelming opposition of the 
vast Majority of the public to traditional Methods of predator 
control and the strong desire of the public to Maintain viable 
populatlona Of wildlife on this nation's land. Siad.larly, the 
anslysia by the U.S. Fish and Wildlife Service of the coiBants 
received on draft and final a.D.C. Bnvironswntal Impact Stata- 
Msnta evoked sinilar definitive conclusions. 

Indeed, the only group in the Fits/Yala survey which 
favored or even approved of traditional predator control 
practices ware the sheep producers and cattleswn, thenaelves. 
Based on the demonstrated and acknowledged inef Eeetiveneas of 
traditional predator control, the support of the industry for 
'more of the Bans' represents moce of an understandable frus- 
tration directed at 'acapegoata" {see page 16) than a consid- 
ered solution directed at a ccoplex problea. 

Unfortunately, the bills in question would tend to per- 
petuate the 'more of the aanie' system rather than provide a 
solution which is both acceptable to the public and in fact 
helpful to the livestock industry. 



The bllKs) does not addrass or provide a solution 
to the overall problems of the (western) livestock 



livestock industry la beset by ■ 



D,B,i..ab,Google 



major problema. Hav Zaaiand and Australia •••n capabl* of 
raising shaap and lambs', shipping lamb, wool, and nutton to 
the United States, and doing both in aueh a way as to ba ccn- 
petitivs with, if not underselling, our own U.S. industry. 
Indeed, if it weta not foe the direct or indirect subsidies 
provided by low public land grazing fees, incentive price 
supports for shorn wool, and import duties on foreign wool, 
among others, pact of the American shoep industry might b* 
largely out of business by now. 

Regardless, however, the presence of a major competitive 
foreign industry provides our livestock industry with on eco- 
nomic problem which it cannot solve, and which the Individual 
rancher can hardly understand. 

Another major problem, which is related both to foreign 
competition and the demand for sheep products in this country, 
is that the Industry is captive of a market in which it is, 
to a large extent, unable to effectively control price and 
must, therefore, accept the offered price. 

Moreover, the industry is admittedly faced with & labor 
supply which has largely dried up. Industry began losing 
herders In the 1940 's to the war and to employment in higher 
paying jobs. The problem continues today, with the children 
of ranchers leaving farms and the industry being unable or un- 
willing to provide wages which will guarantee the retention 
and availability of an adequate number of high-guallty herders. 
And this lack of herders, which is a rcBponse to the real or 
perceived economic condition of the western sheep industry, 
leads directly to both predator and other losses. 

For example, the livestock industry estimates that 50 
percent, or slightly more, of its total losses are caused by 
predators. Accepting these estimates for the sake of dis- 
cussion, the sheep and goat industry is atlll faced with SO 
percent of Its losses which are caused by such oth«r factors 
as disease, weather, and birth-related mortality. All of 



D,B,i..ab,Google 



these fonu of nortality, aa uall as predator-eauaed mor- 
tality, would be reduced by the presancs of adaquate numbeca 
of trained tiardersi aa demonatrated by nmneroua apeciflc 
studiea and the report on "Predator Dainags in the Heat'. 
Freaumably, theae conaiderationa have led the federal land 
management aganciaa to conclude that the lack of herders ia 
one of tb* most significant problems facing the weatern sbeep 
industry. 

Tha economic problems, coupled with a lack cf adequate 
labor to perform propar husbandry practices, hava led directly 
to another phenomenon: the coyote has become both a scapegoat 
and a visible symbol of the distress of an economically 
troubled induatry. Consider this hypothatical , but all too 
real, example: a rancher, seeing a coyote eating a aheap 
that died giving birth, shoots the coyote. The rancher feels 
batter, but he has not solved tha problem. With battar live- 
stock husbandry, both the ewe and lamb would have survived, 
and the death of the coyote would not have occurred. 

In short, providing more money to kill massive numbera 
of coyotes simply will not solve or even address the major 
problois of the livestock industry. Altamatsly, If Congrass 
were to provide a solution to the labor problem (aa ws racom- 
mand at page 31, below) , additional sums for lethal control 
would most likely be unnecessary for preventing livestock 
lasses, as well as being contrary to the public intarest. 

11. The blll(s) fall to awntion, consider, or provide 
protection for this nation's public land wildlife 

To be acceptable, any bill addressing thia issue must pro- 
vide for maintenance of viable wildlife populations on the public 
landa of this nation. To do otherwise would be to treat the 
public lands and values of this nation like the private 
property of ranchers. Hot only Is this unacceptable to the 
conservation coimunity, it is clearly contrary to adminis- 
tration policy. For example, the President stated In a 
1977 message to Congress: 



D,g,tze:Jb.GOOg[e 



'Our Nation'! public landa and watara support a 
rich wlldltf* raaourca which wa hold In truit for 
all Amarlcsna, nov and In tha futura. My Adminia- 
tration will aiaura that thia public truat la ada- 
quBtaly and af factivaly axacutad. ' 

In addition, a* poaltlva, clear, and crainiandabla ■■ tha 
Praaldant'a atatanent waa, he waa in effact only aunmariiinQ 
axlating lav and atatutory nandatas relating to managanent 
of our public land heritage. 

For example, a number of atatutea diractly applicable 
to federal landa and wildlife thereon provide ■ algnlficant 
mandate to maintain viable natural wildlife populationa on 
public land. Among theaa meaningful axpceaalona of tha intent 
of the Congraaa and the people of thia nation to maintain 
wildlife air* the following applicable laws: 



Conservation Programs a 
16 U.S.C.A. S7a, et ■ 
("SyltOB Act-): 



The Taylor Grating Act, 43 D.S.C. 315, et aaq. 

(1970); ~ 

Endangered Species Act, IS O.8.C. 1531-1543 

(1978)1 and 
Forest and Range land Renewable Resources 

Planning Act of 1974, as anunded, 16 

O.S.C. 1601. 



HI. To solve the basic problems of the 









begun by Secretary Andrus's 


memo but. duo 


to limitatlc 


o 






A. Tho Andru£ 







The decision by the Seeretary 
'pradator contr* tfloa: 




b.GoogU 



a decision on pradator control irtilch tor tha ticat tima focuaad 
on 'reducing livattock loaaaa* rather than tha nKire traditional 
'killing predatora'. Hore exactly, Saoratary Andruai 

(1) Lialted tha na* of pravantiva control*, and 
called for tha evantoal phaaaout of pravantlva 

(2) EmphasizBd corrective control, uaing non-lethal, 
non-capture methoda and focusing on offending 
animals. 

(3) Encoutaged appropriate liveatock husbandry 
techniques. 

(4] Expanded eictanalon aarvlces. 

(51 Redirected and refocuaed reaaarch efforts. 

(6) Eliminated denning. 

(7) Limited aerial hunting and other lethal con- 
trol* to areas, tinea, and ways which make 
them as selective as possible. 

(S) Eliminated use of and future reaaarch on 
Compound 1O80. 

I should point out that theae decisions were not developed 
in a vacuum or in responaa to the demanda of a few enviroomen- 
talists. Secretary Andrus made his decision folloving a review 
and recommendations by a major advisory coesiittee, the publi- 
cation of a comprebansive report on Predator Danage in tha Heat, 
and the publication of draft and final Environmental Impact 
Statements. 

Moreover, on the Secretary 'a Predator control Advisory 
riaail I I lis all of those Bsmbers (6) not representing or sup- 
porting tba livestock iaduatry (•nlnaiva of the non-voting 
ChainHn) raeognitad that tha Aniaal "-raja Control program 
was not working and that a fundamental change in direotion 
and e^ihaaia waa needed. To that and, the Advisory Conaittae 
by tie vote (G to G) approved the following recoi^ndatlon i 



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*X 9oal of th* Animal Danuige Control program 
will b« to pr**srve the viability of th* live- 
stock industry through rsduclng livaatock lo***a 
to Bccaptahls levels, ideally without the neces- 
sity of killing wildlife." 

The Secretarial deeision-naking process took a little 
more than t«»o years, and was strictly govern«a by both the 
national Environmental Policy Act and the Administrative 
Procedure Act. Throughout the two-year pariod, the vocal, 
traditional elements of the livestock industry continually 
advocated their favorite remedies for coyote predatlon: Com- 
pound lOSO. other poisons, trapping, increased aerial gunningi 
in short, more non-selective killing. They advocated these 
through and within every possible political forum. The problem 
for the industry was and is, as I have tried to emphasize today, 
that there was no data to support the idea that increased, non- 
selective killing would help reduce livestock losses to preds- 

And, with the notable exceptions of the Animal Damage 
Control personnel and vocal elements of the livestock in- 
dustry, everyone seamed to recognize these facts in the data. 
The general public was violently opposed to continuation of th* 
status quo. The Bureau of Land HanageiMnt, the President's 
Council on Environmental Quality, the U.S. Department of 
Agriculture {through Assistant Secretary Cutler) , and the 
Environmental Protection Agency endorsed, on the basis of 
the data, a program that incorporated most of the major ele- 
ments which were ultimately adopted by Secretary Andnis. 
Theae same governmental agencies strongly opposed on the 
same basis the blind continuation of non- selective, lethal 
controls . 

The environmental conmunity also strongly endorsed st 
least the concepts which Secretary Andrus finally approved. 
Bowever, we clearly wanted and continue to want a faster and 
nor* progrsasive solution to the problems which wa have iden- 
tified throughout this statement. In short, we believe that 
Secretary Andrus erred in not eliRd,natlng all preventive 



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controls at ones, and sharply curtailing that variation on 

preventive control euphemiatically refarred to aa 'cocractiva 



B. Additiona which ahould be made to tha 
Andrua initiative 
Thua, for tba reaaons «• have presented above; 

(1) W« urge that the Congreaa pcovida, through tha 
appropxiationa pcoca**, sufficiant aamarked 
funds to allow racruitnwnt snd training of 
ahae^MCdara. 
(3) Similarly, wa urge Congress to provide funds, 
through the appropriations procass, to regisGar 
and field test the non-lethal, taata avarsiva 
lithium chloride, and to li^^laaant a guard 
dog program. 
It la our bailee and confidence that if theae additiona ere 
made, snd the Secretary's decision with its priorities la 
faithfully inplementad, 'preventive' control and 'corrective* 
control vill die of their own useless, futile weight. 

IV. Conclusion 

In conclusion, Defenders of Wildlife, Environmental 
Defense Fund, International Fund for Animal Welfare, Friends 
of Wildlife, Sierra Club, Fund for Animals, Natural Raaourcea 
Defense Council, Center for Action on Endangered Species, 
Hational Parks and Conservation Association, Animal Protec- 
tion Institute, Friends of the Earth, The Wilderness Society, 
Rare Animal Relief Effort, and World Wildlife Fund strongly 
oppose a.R. 6733 and R.R. 6725. We do this, as ws have stated, 
not because we oppose the livestock industry. Rather, we op- 
pose these bills because they would result in the useless 
destruction of Anarica's wildlife and, would provide only a 



D,g,tze:Jb.GOOg[e 



diveralon that delay* rathac than •nhaneaa th* prompact of 
raduelog llvaitock loaaa* to accaptobla lavala awl aldiitq 
the survival of the industry. 

A ahUt of thia program to tha U.S. Dapartpwit of Xgrt- 
cuitura vould ba only coamaticf DSDA ia govamad by tha *m» 
lawa aa the Departmant of tha Interior, and, Indaad, nSDA 
urged a predator control policy aimllar to tha one adopted 
by Secretary Andrua. Moreover, to tha extent that the bllla 
encourage increased reliance on non-selective hilling of wild- 
life, the racord shows that this provides little nora than a 
false senae of securityi tventy years of Bass deatniction of 
wildlife has apparently done alMost nothing to help tb* In- 

I urge thla Committee to strongly support Secretary 
Andrua' s decision and provide the funding that we have re- 
quested. Secretary Andrus made a commendable and tough de- 
cision. Be, as a former Hestem governor, decided to provide 
a dacialon for the livestock industry that gave them what 
they needed. Instead of tha counterproductive and largely 
■uparficlal solutions that they advocated. I urge thia COM- 
mittee to carefully study the record, adopt a similar view, 
and provide the industry with concrete help trtiich we have 
suggested and lAich it desperately needs. 

(Tha "Draft Eaviroawntal SCatBiuDt" la held la tha subco^ttM 
tlla. Dthar attacbuata follow:) 



D,g,tze:Jb.GOOg[e 



T#atimoQy, Fi<tur« Ho. I 
U^ S(ock Shmp aid Lunb Numbwt 




■ D.S.D.*. tepoct I 377 



D,g,tze:Jb.GOOg[e 



u on U^. FOfnt Sanica Lwids, IKO-ISTB. 





ToCi 


,g»lm«cl Cauiwol Loun 


ToU! 


Kerf 
Total 


*r£ 




PcAor^^ 






Toiil 


Year 


Gniea 


Pii.ia 


Prj^lon 


OthBT 




Gniad 


yai 


1940 


4,95B J77 


26,432 


67580 


58.564 


1S2.338 


130 


44 




4.79Z794 


25,160 




53,428 


143.888 


136 


45 


1M2 


4.781 JH2 


23.875 


82,372 


52J8S 


138,412 




4C 


1943 


4^*1.878 


23,345 


88,474 


48.197 


139,016 


1.48 


48 


1«4 


4,283.767 


. 21544. 


63233 - 


45.684 


130,241 


1.48 




1949 




17X9 


69»1 


39.588 


123.118 


138 




IMe 


3.730120 


20.418 


99,907 


. 38.721 


110348 


130 




1C47 


3.404.598 


14,743 


48mZ 


37.1M 


98,000 


139 




1B4a 


3.324.485 


14518. 


30.477 


35.800 


80399 


032 


38 


1949 


3.095.685 


12,820 


28M9 


32^81 


73,758 


033 


3S 


1950 


3.010.685 


10»2 


23M7 


27.107 


81356 


0.70 


SI 


1951 


3J)18il8 


11,725 


25,224 


31.28S 


88,214 


034 


37 


isaa 


3.004.882 


■ 11,580 


24,502 


30J29 


86391 


032 


ST 


1953 


2,997 J3a 


11J*6 


24,382 


30.821 


E6.329 


032 


37 


1954 


3J}1B,SS8 


. 11,281 


29.189 




70.918 


037 




1955 


2,922,031 . 


10.787 


29,462 


27308 


64.155 


037 




1956 


2.BZ7.929 


11,178 


27,240 


33.708 


72.124 


036 




1957 


2,709.875 


9.4SZ 


21,880 


25372 


57384 


030 




1958 


2,696.760 


9,629 


22,875 


25351 


58.255 


034 




1999 


2.569.814 


8.881 


23.108 


25373 


57.962 


030 




1960 


ZJSTSJSBB 


9^009 


28,481 


23,861 


61 .151 






1981 ■ 


2,460.577 


9J57 


25,534 


25,284 


KJOTS 


lis 


43 


1962 


2,387,084 


a.531 


24M5 


19,577 


92.973 


135 


■O 


1963 




8.104 


27,616 


20558 


55378 




*i 


1964 


2^03,016 


7.121 


28^82 


18365 


52368 


1.18 




1965 


Z099,eiS 


T.057 


26.183 


20,543 


53.783 


1.25 




1968 


2,071.228 


7.3M 


30.747 


20,188 


58.334 


1.48 




19CT 


1.972,^ 


8507 


96.785 


21,791 


55,483 


138 




19S8 


1,910,876 


8.560 


.27.235 


17353 


51,448' 


1.43 




i9ra 


l.e«S,434 


5.828 


34353 


21344 


- 82,725 


137 


56 


19T0 


1,780^57 


6A» 


32,639 


18,175 


54.814 




GO 


1971 


1,737.T72 


S.31S 


12.075 


19366 


59,778 


135 


56 


1972 


1,702,133 


S4ia 


40.686 


19,S72 


65.874 


239 


62 


1973 


1J1S,352 


B,«7 


31.331 


19,736 


57.574 


237 


54 


1974 


1,422.766 


5,502 


38387 


10.219 


81.888 


230 ' 


S3 


1975 


1,465.492 


3K2 


31.786 


14,049 


49,737 


2.17 




1878 


1,748.163 


4«9 


32579 


15,405 


52.893 


138 


62 




. a Souroe, pag» 31. Predator Di 



D,B,i..ab,Google 



Defenders 

_/ OF WILDLIF 



y^^. / 



July 14, 1979 



Hr. SC*v«B P. Fraudanthal 
Bxacutlv* Assiatant to tha Saczatary 
Oapartvant of tba Intazior 
Waahlngton, D.c. 10340 

Daar Stavat 

Thla l«tt«r rapraaanta acne Ini-tial e 
aerlouily inaccurate and miileading matarlal found in tha 
curcant Final Environmental Impact Statamant on the Aninal 
Damage CanCrol Trogcam. It is our vimn tbat tbaaa inaccuxa- 
eiaa aza of auch significance as to require that an arrata 
abaat ba pro«nitly issued concerning the portions notad. 

On Kovambax 13, 1978, the Office of Audit and Invasti- 
gation prepared an analysis of the operation and financial 
mansgenient of the Animal [laBaga Control Divialon of tha Fiah 
and Mlldlifs Service- 

The results of that Audit were disappointing to u». In 
effect, tha report concluded thst financial controls and ad- 
Bini s tret ion of the Anijnal Damage Contiol Program were aerioua- 
ly IsjE- Host disturbingi bowever, was the conclusion that up 
to la million dollars was being spent, with rto indication that 
h expenditures are of any significsnt valua In raduclng 
. ^ predatlon. 

In apita of thaaa and othaz deficiencies In tha data and 
pirogram nated in your Audit Keport, a Final Environmental Im- 
pact Statement on tha ADC Frogrsm has now been issued which 
Includes a table (paga 141] and discussion (pages 13S-14Z) 
which essentially purpost to show the value of the ADC Prograa 
in terms of livestock aavad, and tba value thereof 

Defenders of Mildllfe ia qalta concerned with tha table 
and relevant discussion because (a) the presentation in the 
Final Environmental Impact Statement Includea no mention av 
discussion of the Audit or the Audit findings, (b) the presen- 
tation in the FEIS seems to seriously contradict the findings 
contained in the Department audit Of this same program, and 
<c) the presentation in the FEIS contains serious errors of 
fact and logic which are both inexcusable and nialeadlng. 

c catagocy ara tha 



1244 NINETEENTH STREET, NW a WASHINGTON, DC 20036 • (202) 659-9510 



db.Google 



. Serious inAccuracias axist with respect to calculation 
of the average sheap Iobb rates used in Tabic 3-17, 
page 141, FEis. 

Study sites tot the referenced predator control/ live- 
stock loss studies were not randomly selected. Tar 
from it. Undoubtedly, these study sites were areas 
In which coyote depredation was reported since the 
purpose of the studies waa to docwoent coyote depre- 
dation on livestock. Indeed, scna of the study sites, 
such as the Cook ilanch (Henne, 1975] , were selected or 
allowed to be used specifically because of high annual 
reported loss rates. 

That the study sites were not randomly selected is wb.- 
phasized by the results of the recent D.S.D.A. study 
(Ge* et al., 1977) where it was found that 45 percent 
of the western ranchers surveyed suffered no ewe or 
lamb loss and 67 percent of such ranchers suffered no 
sue loss. 

By definition, then, the studies used by the 7ish and 
Wildlife Service, to the extent they are at all "typi- 
cal'*, are typical only of the relatively small number 
of ranches where reported loss rates are aubstantial 
and significant. Clearly, these loss rates are in no 
way typical of loss rates for westwide livestock in- 
dustry given the results of studies by Balser C1974] 
and Gee et al.(19T7). 

An earlier complaint to the Fish and wildlife Service 
on this same subject involving the identical figures 
used In ths ADC DEIS (Decenber 1978} brought total 
agreement with tny position (see attached! . In fact, 
7WS Associate iSirector, Dr. F. E. Hester, stated In his 
January 30 1979 reply to ms: "He appreciate your re- 
marks the implication that they /derived loss rates7 
are somehow typical of the loss situation westwide will 
be corrected in the final CIS.* Bowaver, as evidenced 
in Table 3-17 these inplicetions have not been cor- 



*Another set of derived loss retes cited In the FEIS tp, 
45) as being from FWS USTBa) , which was the Report on 
Predator Damage Management in the West, are inaccurate 
for reasons identical to those stated herein in U.) 
above. These loss rates were formulated again -using 
predator loss studies In ranches where high, losses were 
regularly reported. Hence, derived lose rates and re- 
sultant calculations are only applicable to those rela- 
tively snail nunber of ranches where high losses occur. 



D,g,tze:Jb.GOOg[e 



. Ssrious errors of fsct and logic were made by apply- 
ing d*rivad loss rates to Che total western livestock 
Inventory In determining 'estieiated lOsa*. 

The U.S.D.A. eatimated (Gee st al. , 1977} that 45 per- 
cent of weatern ranchers suffer no ewe or lanb loss and 
67 percent of western ranchers suffer no ews loss. These 
results essentially agree with those of Balser (1974J . 
SiinUarly, the FWS estimates that the ADC operation "pro- 
tects or impa.cts' about €6 percent of western sheep 
(Table 1-11, page 43, PBIS) . 

However, the admittedly high •stinates of loss rates 
[discussed in (1) above) are multiplied by the total 
western liyestocli inventory to determine estimated 
losses with and without predator control. Obviously 
since the loss rates apply only to areas where losses 
occur, and since only about 55 percent of ranchers 
suffer any lamb losses and about 33 percent of ranchers 
suffer any ewe losses it is incorrect to multiply de- 
rived loss rates as calculated) by the total western 
livestock inventory to compute estimated loss. 

. Apart from the above. Table 3-17 (attached) also in- 
pliea seriously misleading information. Information 
on page 140 essentially states that the line entitled 
"Possible loss without control" should, to be accurate, 
ba titled " Maximum possible loss without control. The 
omission of this word ia obviously important to how the 
table la interpreted by the reader. 

Similarly, the following line, "Difference in loss, 

with and without control" should read " Maximum pos - 
sible difference in loss, with and without ( current ) 
control". The omission of these words, again, has a 
tremendous li^act on how one interprets Table 3-17. 

, in our 



The referenced discussion Of the value of the current ADC 
Progrant is obviously of critical ixportance to a cooplate under- 
standing of this program by Secretary Andms and the Interested 



D,g,tze:Jb.GOOg[e 



Ai dlBcussad herein, ouz anftlysla auggcsti that tha pra- 
••ntation on p«g«a 138-143 of tha FEI5 nakes a aockary of the 
concluBionB and evaluation contalnad in th« Audit. Furthar 
and mora sarloualy, for the raaaons contalnad in tha Audit and 
In thia letter, the Secretary and tha public are potentially 
to be praaantad with biaaad, Inaccurata, and mialaading infor- 
natioa on which to baae an extxwnely ii^ortant decision. 

Pleaae underatand that we do not naintain that the cur- 
rent Animal Damage Control Program la of no value to anyone, 
or that coyotaa do not kill sheep, tte do naintala, on the 
baaia of the figures praaentad, that tha value of the current 
program in the FBIS la aerioualy and deaonatrably ovaratatad 
and that auoh an ovaratatamaut could oauae a major blaa in the 
evaluation of the current program and alternative progzaaa by 
both the Secretary and tha public. 

Accordingly, we urge you to iaaue an azzata sheet con- 
cerning tbeaa cBlculationa aa quickly aa possible, and to 
provida. in auch an errata sheet, some discussion of the re- 
' lation between this document and tha Deper-Uaent ' a own audit. 




D,g,tze:Jb.GOOg[e 



Januaxy 9, 1979 

□r. P. Eugen* Bastec 
Associate Director 
Environjnent and Has ear ch 
U.S. Fi£h and HildUEe Service 
Department of tha Interior 
Washington, D.C. 20240 

Bei Denver Wildlife Seaeercb Center'a Opinioa, 
Page 105 of tbe DEIS (#78-49) on Predator . 
Control 

Dettr Qz. Hester: 

I am addreaaing thia letter to jfou aa tha Govamment offici»I 
responsible for superviaing the oparation of the Danver HtldliZe 
Research Center. Dnfortunately, we have diacovered certBin In- 
accurate statenents which threaten the czedlbility and objectlvi^ 
of tha Center. j j 

Defenders of Hlldlife ia currently conducting an In-deptb 
review of the Draft Environmental Impact StataMent on the U.S. 
Fish and Wildlife Service's Kanmalian Predator Damage (tanagment 
for livestock Protection in the Western Onited Statea. In that 
regard, we were particularly dlatresied by the-Denver Center's 
'opinion' referenced on Page lOSi 

■It ia the opinion of the.t>enver Mlldllfe Research ' 
Center that those studies with control are typical 
of losses expected in areas where control is applied; 
however, the percent of loss in the studies without 
control may ba low due to external inflaencea snoh 
as trapping and aerial hunting In and adjacent to 
' the study areaa.' , ■& i ., 

This opinion presumably tends to lend credlbiUty to derived sheep*- 
loss rates of "1.9 to 6 percent" In areaa with predator control. , 
and loss rates of "13, 36,3, and 7.6 parcenf in areas without 
control. It is further suggested that these studies are repre- ' 
sentative of Areas with "(1) ongoing predator oontrol, and 
(2) without or -very limited ccmtrol.* 

The endorsement of the Denver CenteK of these lose zatea 
the apparent endorsement of the repreaentatlveBesa of areas, and 
the were mention of an endoraenent by the Denver Center In rela- 
tion to the material on Page 105 surprlae ua Cor the following 



1144 NINETEENTH STREET. NW • WASHI»«CTON. DC MOM • QOI) 6194910 



D,g,tze:Jb.GOOg[e 



1. study sites for these "predator control/live a toe Jc lost 
studies- Bce not randomlv selected. Far from it On- 
<lDubteaiy, these study sites, were aceaa in uhich some ■ 
coyote depredation was reported since the purpose of 
the studies was to document coyote depredation on live— 
BtocH. Indeed, aone of the study sites, such tts the 
Cook Ranch (Honne, 197S) , were apparently selected Or 
-ii™.^ ♦„ >, ;. — ,cificaUy because of high annual 

That thm Btudy alt^a vara 

aizcd by tbm reculta of t ^__ 

•t ■!., 1977) "Iwr^it vas found that'ii'pMcrat'of th* 
mm A ._. ,j io«» and 87 

losa. 

By definition, tbm, tba ctnOi** u«ad b; the riah and 
Wildlife Service, to the extent thery are at all -typical- 
ore typical only of the relatively small number of ranches 
where reported loss r«t«s are ■ubstantial and significant 
Clearly, these loss satea are in no vay typical of loss 
rates for westwide livestock IniJuatry given the results 
of atudlM by Balsar (19741 and Ge e et «1. (1977). 

2. Knowledgeable Interior Department officials connactad 
with tba Cook Ranch study have described the losa rates 
found in tha Cook Ranch study as "atypical-, 'worat case". 
and "excessive- Baaed on these opinions from knovjledge- 
able persons (largely conlirroed by Balser, pars, conn ) 

it Is untenable that these results could be referred to' 
as "typical* . 

3; The quoted total loaa ratea for those studies xitb con- 
trol and those stuilies without control vere incorrectly 
cciVnted. In ccoiputing the loss rates (expressed as 
parcaats] , the loss rates for eweS and lambs were added 
to derive a loss rate ior sheep. Por example, tlia qootad 
3S.3 percent loss rate for sheep (in the Eenne 1975 atndy) 
was apparently derived l>y adding the 7.S percent •»• loaa ' 
rat* to the 28. B percent lamb loaa rata (see Page 230, 
Study >o. 7) . Loss rates for the other quoted stadias 



(Hos. 9, 10, 3, 5, 2} ware calculated in the a 



» vay. 



This »etbod of calculation results in a 'sh^p loss rat 
that is precisely double the actnal rata, if we assima 
111 ratio of ewed to lambs. If the ratio is awtbina 
othar than 1:1, tha loss rate for ahaep can ealy bacos 
putad by using a fomiila for a weigh£ed average. 



D,g,tze:Jb.GOOg[e 



4. The inflated abeep los« catctf ar« av«rag«a to achiavw 
theoretical westvide Iob« rates, with «nd without con- 
trol These rates are aubtracted to d«rive a theoreti.- 

We have other concens about the derivation ot these 
inflated loss rates. The averages are based on a sam- 
ple of only three studies each, from widely scattered 
areas in different years. Statistically derived confi- 
dence limits are not provided. The reader is not advised 
that the sample size is so small, and the conditions so 
variable, that statistically valid calculation cannot 
he made. Nor is the reader advised that without better 
data all the conclusions are without validity. 

5. Subsequently, the calculations mentioned above feaa th* 
basis for conputlng an inaccurate extrapolation tO" « 
■monetary savings' of $93,819,600, The result of this ' 
extrapolation is probably even more inaccurate and In- 
flated than the above inaccuracies alone would eaus* 
since there also seams to ba scne snbsttatial Inflation 
in the number of 'sheep protected.* 

Gene, I find it unbelievable that the Duver Center endorsed * 
may of the calculations on Page 105 of the DEIS. If It did, 1 ng- 
gest that the pzocadures for providing endorsaments by responsible 
rederal Research Centers need to be tightened aobstantiaU^T^ 

In any event, the mere mention ot the Dan^ex Wildlife Beseer^ 
Center in the conteict of the obviously Ineocnrate and poorly con- 
ceived calculations appearing on Page lOS can oalj seriously nnder- 
Mine the credibility of the Center, 



latlona and t±» extent of it:s endorsement. 

Thank you for your attention to this Batter. 
Sinoerely, 



eei Bon. Cecil D. Andrus 
Bon. Charles warren 
Bon. Robert I,, Herbst 
Bon. Richard J Myshak 
Bon. I.ynn A, Greenwalt 
Mr. Richard D, Curnou 
Mr. Cordon T. Blghtlngele 
Hr: Clarence Faulkner 
Interested Parties 



D,g,tze:Jb.GOOg[e 



United States Department of the Interior 



In K«plr Utn To: 



• Tic* P 
Dttodar* of Wlldllf ■ 
W* 19tb SttMt. m 



Dear Dr. Ciandj: 

This raspood* to jdiit latcar of Jmuarj 9, 1979, caf intlng on tha FIA 
and Hlldllfa Sirrlca'i Draft Enrl L O umu tal Iiipact StaCoant (ZIS) aa 
lla^al liii Fradstox Daaifa HutataaaBt for Llvaatock Protacclon la tha 
Vaatam Italtad Stataa. 

Tou ara corract In aCaClng that tha altaa aalactad for tha "pradacor 
coBttoI /llvaatock loaa atudlaa" ara not typical of tha Hatvlda ahaap 
Induatry. Thalr aalaettoa ma cartaliilr not rasdoa. Ihaj wara aalactad 
bacauaa tha Invaatltatora InvolTad knav that loaaaa to coyotaa vara to 
ba axpaetad, thua aaklni laaaarch on tha attacta of control m lack 
of eontnl poaalbla. Ua appraclata jrour rMarka; tha l^llcatloa that 
tbay ara aoaahov typical of tha loaa altuacioB waatiiUa vlU ba 
eortaccad In tba final US. 

Toux co^Hnt on tha loaa fliuiaa la alao wall takan, Tba data wara 
pcoparlj coLIactad and praaancad In tha orljinal laporta, and tba 
fifaraa will ba corract In tha final EES. 

Wa Bppraelata your bringing thaaa Itaia to oar attanclaa. 

Slncaralf TOiuca, 



Aaaoclata Dlractor-laaaaTch 



D,B,i..ab,Google 



Tabic 3-17. 
CoD?>rIC(ia of Sheep Lo«iai to Coyotas 
Viih *.at Vichouc Fradator Coacrol 

E1.1S 



LOSSES WITHOUT PKDATOR COHTSOL £2 KOXED) . 

On« Hontaca ranch (avarasa 1974-75)(('^*-* J 7.8 

One Keu Haxlco ranch (avenge 1974-75) 0.45 

One CiUforala flock <anB«C 1976) 1.4 

Arcragaa 3.2 



LOSSES VI7H ntEDAIOS CIKITBOL (Z KHISS) 
Ona Mavada flock (1973) 
Nine Idaho Ilocka (avera|a 1973-75) 
Ten Utah tlockt (average 1972-75) 
Flva UyoBins flocks (avatasa 1973-75) 



H SHEEP IKVItnOSY, 1977 
(slllloiis of I heap) 
1STIMAT3D LOSS WITH PREDATOa COilTTOU 



(1.0(D head) 
(value, S allllonaT 




43.7 
1.85 


281.3 
1«.0 


POSSIBLE LOSS WITBOIIT COHIXOL 
(l.QOO faaad) 

(value, S BllllonT 




279.9 
11. S5 


974.6 
55.6 


DIFFES£KCZ IH LOSS, UITH AND HITROtlT C0EI7S0L 
(1,000 haad) 


235.8 


693.3 


(valua, S Billion) 




10.0 


39.5 


EarvU« (197E 11-25. aoureai 2-5 and 7-10). 



2/ Froa Table 1-10 
3/ Stock aheep. Boat of which ar« braadlng ox raplace^at swai. 
y BaMd on valua* par head of $42.40 aod $37.00 for «t«ek aheep 
viA lasba, raspaetlvaly. 



D,g,tze:Jb.GOOg[e 



Mr. DE LA Gabza. Mr. Kandall, do you have a statement or com- 
ment to make, sir. 

Mr. Randall. No, sir. I helped to prepare this statement. 

Mr. DB LA Gahza. Thank you. Mr. Wampler? 

Mr. Wamplbb. Thank you, Mr. Chainnau. 

Dr. Grandy and Mr. Kandall, I appreciate both of you coming and 
appearii^ on behalf of yourselves and the oi^aaizations that you 
represent. 

You have given us a very comprehensive statement and one to 
which I would like to give additional study and thought if time presents 
me the opportunity. 

I gather, from the thrust of your statement, Dr. Grandy, that you 
feel that the statistics that have been given to this committee by the 
livestock sector that indicate they are suffering substantial losses due 
to predators are overstated. Is that correct? 

Mr. Grandy. Based on the data, yes, sir. As I said in my statement, 
at least the mail survey data and, indeed, even the method of calcula- 
tion used by the Fish and Wildlife Service to estimate losses are biased 
for reasons that I gave in my statement. 

I do not deny and, indeed, understand that individual losses on 
individual ranches do occur. That is clear from the data. 

What is inaccurate in the way the figures are put together is that 
they take data from those areas where losses are highest, average a 
few ranches, and apply those figures westwide. We know, from USDA 
studies, from Mr. Randall's work in Wyoming, and the work of our 
other field representatives throughout the West, that livestock loss to 
predators is a spot occurrence. It is localized. 

The Fish and Wildlife Service recognized that years ago. That ia 
wW an average solution to the problem simply will not work. 

Mr. Wampler. On page 14 of your statement you said : 

Indeed, it it were not for the direct or indirect subsidies provided by low public 
land grazing fees, incentive price supports for shorn wool, and import duties on 
foreign wool, among others, part of the American sheep industry might be largely 
out of business by now. 

You also refer to the fact that New Zealand and Australia seem 
capable of raising sheep and lambs. Are you aware of any government 
regulations that exist in New Zealand and Australia that are similar 
to those facii^ the American industry? 

Mr. Grandy. No; I am not familiar with New Zealand's or 
Australia's regulations. 

Mr. Wampler. What types of predator control programs do they 
have in New Zealand and Australia? 

Mr. Grandt. I am not familiar with them. 

Mr. Wampler. That could be a very significant reason why the 
cost of production is so much higher in the United States. We find 
this repeatedly concerning regulations that are placed on all s^ments 
of American agriculture. It is something that is very basic and 
fundamental. 

These costs due to regulations have to be passed through to the 
consumer who is the one who ultimately pays the bill. 

We are trying to address some of uie causes of inflation in this 
country. Needless Government regulations are a contributing factor 
to our decline in productivity. 



D,g,tze:Jb.GOOg[e 



167 

I think this is a significant point. You are making a comparison, 
saying that (arm producers in New Zealand and Australia can produce 
cheaper but we need to know why. Are we competing on the same 
basis or are we regulated on the same basis? 

Mr. Grandt. Clearly that is so. Do they have to support the same 
public land values under their constitution that we must support 
under ours? 

Mr. Wampler. However, you are not aware of the differences in 
regulations. 

Mr. Grandt. No, I am not, but one point should be made. Even to 
the extent that there are differing predator control regulations in this 
Nation from those in Australia which are a factor, you are still dealing 
with a highly localized problem. 

Mr. Wampler. I do not dispute that. What I am saying is that you 
made a comparison without knowing for sure what the difference in 
the regulatory situations is. It could oe a significant difference. 

Also, on page 18 you indicated your strong support for the decision 
of Secretary Andrus in his memo of November 8, 1979. Could vou 
enlighten us on why you feel the Director of the Fish and Wildlife 
Service did not agree with that statement of policy and why the 
Assistant Secretary of the Interior, who has direct jurisdiction over 
this area, also disagreed with the Secretary? 

Mr. Grandy. I think they made a mistake. 

Mr. Wampler. You mean the Secretary made a mistake? 

Mr. Orandt. No. I think the Assistant Secretary made a mistake 
to the extent that he disagreed, and the Director did to the extent 
that he disagreed. Clearly they were in error. 

Mr. Wampler. Oh, I see. 

Mr, Grandt. The only continuous time stream data that exist for 
the western livestock industry in terms of predator loss and livestock 
numbers, et cetera, indicate that the advent of lOSO and, indeed, its 
continued massive use never worked anyway. 

There is no reason to study in minute bits 1080 anymore when 30 
years of data show that it does not work. 

Mr. Wampler. That statement is contrary to much of the testi- 
mony that we received yesterday from people who are rather eminent 
in the field of science who felt, to the contrary, that we should continue 
this research to find the answers. 

One of the reasons, apparently, that the Secretary of the Interior 
gave for his decision was that it is too politically sensitive, that he 
was fearful of lawsuits, and it was not a politically acceptable decision 
to do otherwise. This leads me to believe that, simply because the 
Secretary of the Interior refused to accept the recommendation of the 
professionals in hk own Department, it was more of political decision 
than a scientifically sound judgment. That happens to be my feeling 
on the subject. 

Mr. Grandt. I understand your point but my guess would be that 
the Secretary considered a variety of factors in making his decision, 
not the least of which was the fact that 1080 never worked. 

I want to address one additional problem — I was not here yesterday, 
but Mr. Randall was here for the duration of the hearing yesterday. 
The opinions that I saw presented in the testimony, which he brought 
back, clearly demonstrate just what we have been talkii^ about 
through our whole statement. There are a lot of opinions that 1080 
might work. 



D,g,tze:Jb.GOOg[e 



168 

The only continuous data that we have of operational control for 
30 years snow that it does not work. All opinions to the contrary, 
the Secretary was forced to make, by virtue of law, his decision on 
the basis of the data. 

Mr. Wamplbr. I would have to respectfully say that apparently 
there is a division of opinion on that amoi^ scientific authorities. I 
think the literature shows that there is a division. 

Mr. DE LA Garza. Will the gentleman yield on this point? 

Mr. Wamplbr. Yes. 

Mr. OB LA Garza. I would like to read from a letter which I re- 
ceived, dated April 10, 1980, from Mr, Daniel A. Poole, president of 
the Wildlife Management Institute. In part the letter reads: 

You should understand that the institute is not unalterable opposed to the use 
of 1080. Very recent research results reportedly indicate that the compound can 
be a highly specific poison for coyote control when meticulously applied at the 
proper time and places by competent individuals. 

Use of 1080 in the new toxic collar being developed may be especially effec- 
tive. Consequently, we do not think that the application of 1080 should be 
ruled out completely. 

Mr. Grandt. I, and certainly the organizations that I am repre- 
eentins today, disagree with that. We find no support for it from the 
data that we have reviewed. 

I think there is a more significant problem, if I may just address it 
for a moment, particularly with respect to 1080 but also with respect to 
any of the nonselective secondaiy poisons that we have used. The data 
do show that they do not work. The problem is that those poisons — the 
potential for their use and, indeed, the argument that we are going 
throi^h here today — are providing the industry and, I believe, in 
some cases yourselves with false hope that something is going to 
happen and are stopping us, the conservation community and the 
Congress and the industry from agreeing to give the industry the 
heJpit needs. 

What it needs, as the Bureau of Land Management sud, as did the 
Advisory Committee on Predator Control of which I was a member, 
is — the single most significant problem facing that industry is the lack 
of adequate labor. Apparently, there was no predator problem pre- 
1040. The industry reached its zenith before any of these chemicalB 
were ever developed. 

The idea that we have to go get these chemicals now is simply a 
diversion that is stopping the industry from addressing its real prob- 
lems, and it is, indeed, stopping the Congress. 

Mr, Wamplee. If I may follow up on that, on page 21 of your 
statement you recommend some additions which should be made to 
the Andnis initiative. For example, you ut^e that the Congress 
"provide, through the appropriations process, sufficent earmarked 
funds to allow recruitment ana trainii^ of sheepherders." 

From where would you propose to recruit them — in this countiy, 
abroad, or where? 

Mr. Grandt. In either place. If I recall, this morning Qenerat 
Motors laid off 10,000 more people yesterday. There are probably going 
to be a lot of people looking for employment very soon. 

Mr, Wamplbr. Do you think many of them are going to go out and 
become sheepherders? Do you think that? 



D,g,tze:Jb.GOOg[e 



169 

Mr. Grandt. I think, of course, you have to proyide wages. You 
cannot ^ve nothing to these people. 

Mr. Wampler, Let us be a httle more specific. What would you 
consider to be a fair wage for a sheepherder? Would you say the mini- 
mum wage? 

Mr. Grandy. I am not familiar with that detail. I have been with 
sheepherders and I have been on the open range with them, but I 
never asked them what they made and I never asked them what they 
considered fair. 

Mr. Wampler. Obviously, then, you have given no thought to what 
the cost estimates of these recommendations are that you made. 

Mr. Grandt. I have given some thought to the cost estimates. 

Mr, Wampler. Will you share them with us? 

Mr. Grandy. My first thought is that we are pending nearly $18 
million, as the Interior Department's own Office of Investigation said, 
without being able to show that we are helping the livestock industry 
one whit. 

BLM suggested that a great part of that $18 million be used to train 
and equip sheepherders and to subsidize them if it is necessary. 

The Congress has provided, and I do not say incorrectly, numerous 
subsidies to the livestock industry. I think this is a subsidy that would 
really help them. Yet it is one that has been consistently avoided. 

I suggest that you would have the broad support of the livestock 
industiy as well as the conservation commumty for those effort 

Mr. Wampler. I asked this question of a number of the witnesses 
yesterday. I think, without exception, they said that type of labor 
simply was not available in their areas. 

Mr. Gbandy, If you do not pay for it, it is not available. 

Mr. Wampler. That may be another question. They just said that 
this was maiginal type labor. It was not available and that they could 
not bring foreign nationals into this country because of the restrictions 
on it. Apparently, they have tried it. At least that was their inference 
in the testimony yesterday. 

You make a suggestion and, again, when I ask for a specific — ^you 
have given me one. You suggest transferring the $18 million over to 
this. If it is going to cost that much, at least that is an effort to quan- 
tify it. 

Let me ask you this. Have you or any of the oi^anizations that you 
are representing here this morning ever sued the Secretary of the 
Interior, that is, brought legal action against him? 

Mr. Grandy. Yes, sir. 

Mr. Wampler. Was it on a continuity basis? Does it occur with a 
gieat deal of regularity or what? 

Mr. Grandy. I cannot speak for all of the other oiganizations. 
Defenders of Wildlife has sued the Secretary. I think we sued him once 
in 1979 and once in 1980. 

Mr. Wampler. I was kind of curious since that was one of the 
justifications for the issuance of his new statement of policy — fear of 
law suits. I just assumed the Secretary is sued almost daily. Many 
of the laws that he administers are of a controversial nature 

Mr, Grandy. That is clearly correct. One thing is that we have 
been winning a lot of the lawsuits. The Secretary does not have to 
worry about us winnii^ if he is complying with the law. 



D,g,tze:Jb.GOOg[e 



170 

The only standard that exists in the laws under which he was 
operating in making this decision are the arbitrary and capricious 
standards which, as Congress knows and as lawyers well mow — I 
assume most of you are lawyers — are the hardest suits to win. The 
only way you can win an arbitrary and capricious suit is to show that 
the Secretary did not make a decision on the basis of the data. 

To the extent that he did not endorse the use of 1080 because he 
was fearful of the results of lawsuits, I suggest says something about 
the quality of the data. 

Mr. Wamplbb. I am not implying that you do not have the r^ht 
to sue him. I would be the very first to defend your right to do that. 

Let me ask you one final question. This is in the nature of a hypo- 
thetical. Most of the testimony has revolved around the coyote as 
being the principal predator responsible for losses, particularly to the 
sheep and goat industry in this country. While I am sure there are 
others — the golden eagle being one — coyote seems to be the main one. 

If we were of a mind to do so, do you feel that using every known 
method, that we could exterminate the coyote in th£ countiy and 
render him an absolutely extinct species? Would that be possible in 
your mind? 

Mr. Grandt. I am certain it is possible. 

Mr. Wamplbr. You think it is possible, 

Mr. Grandt. Of course. Anything is possible. 

Mr. Wampler. Do you think the coyote is in any immediate danger 
of becoming an endangered species in the country? 

Mr. Ghandy. I doubt it, although its populations are clearly 
reduced in some areas. It depends upon whether you are speaking of 
local geographic areas, statewide, countrywide, or nationwide. 

Mr. Wampler. Will you tell us, in your opinion, is the coyote 
population larger today than it was 10 years ago in the country as a 
whole? 

Mr. Grandt. I have not done any specific research. The only data 
of which I am aware are trend indexes provided in the final environ- 
mental impact statement which show that coyote populations have 
been reduced over laiye portions of the West in recent years. I am 
not familiar with the last 10 years specifically. I could certainly re- 
fresh my memory from those tables and provide the answer for the 
record. 

Mr. Wampler. It would be fair to say that there is no immediate 
danger of it becoming an endangered species. Is that correct? 

Mr. Grandt. You are asking about the species as a whole, and I 
would say , not nationwide certainly. 

Mr. Wampler, I again want to thank you for a very compreheosiTe 
statement. I assure you that I will carefully review it. 

However, I must say candidly, as one who has served on a com- 
mittee that has some responsibility to help assure an adequate supply 
of food and fiber not only to our population hut to much <n the 
world, that we have to be examining ways to increase production. 
As a consumer, I want to get the best quality food in this countiy 
at the lowest po.'jsible price. I think we all want to see that hi^pen. 

Here we have an obvious conflict between l^itimate concerns for 
the environment and for wildlife on the one hand and then, on thtt 
other hand, the pure economics ot production. 



D,g,tze:Jb.GOOg[e 



171 

It WAS testified to yesterday by the commissioner of agriculture in 
Texas that there is a tremendous potential for export markets, par- 
ticulu'ly for lamb, that cannot be utilized. I think we have put a 
great deal of emphasis on loss of production in these hearings. 

I think what we also need to look at is what the potential for in- 
creased production would be if we had some effective way of mini- 
mizing predator losses to the livestock industry. Apparently, a lot of 
people made the decision to get out of it simply because of this, and 
other reasons, one of which is mflation and the increased cost of pro- 
duction. That is also something that this committee needs to look at. 

We should ask: Is there a reasonable way that we can satisfy every- 
one's concerns? I am not sure that there is, but I certainly want to 
tr; to find it. 

Mr. Grandt. As I understand it, this committee also has respon- 
sibility for significant segments, through the Forest Service and other 
servir«s, of the public lands of this Nation and it understands the 
necessity of maintaining viable wildlife populations. 

Mr. Wamplbr. Oh, yes. We definitely want to do that. 

Mr, Gbandt. That may, in some cases, be a necessary and built-in 
factor in your least cost equation. 

Mr. Wamplbr. Yes, sir. I quite ^ree with you. That is what we 
will attempt to do. 

I do, again, want to thank you for your very fine statement. 

Mr. Randall. I think, Mr. Wampler, that one of the reasons why 
we are not getting changes ia that the status quo is always such a 
comfortable thing. To deviate from something that we have done 
for so many years is really a challenge. To go off in a different direction 
and learn new things in trying to solve a problem is a heck of a chal- 
lenge. 

I think somebody has to take the first step and get out and prove 
that some of these things will work in solving the problems. 

Mr. Wamplbr. I agree that that is a worthy wiought. The thing 
that does concern me, as 1 stated yesterday, not particularly in the 
case of the Secretary's memorandum of last year, is what the regula- 
tory agencies right across the spectrum of Government are doii^g, 
mating political decisions and not relying sufficiently on the scientific 
data available. 

This is why I am at a loss as to why Secretary Andrus decided to 
terminate any further research on 1080 when people I have talked 
to who have testified before this committee say that they are making 
progress and that it did offer hope. It leads me to conclude that the 
Secretary made a political decision rather than one based on sound 
scientific data. I just have to feel that way. 

I can cite you any number of instances — the USDA and FDA on 
nitrites as a preservative in food. We have any number of these before 
us at the moment. We need to start making these decisions on the 
basis of the best scientific data available, not on the basis of whims 
to satisfy one interest group or the other — livestock producers or 
whoever it might be. 

Let us go to the laboratory and try to find answers to these things 
rather than having them made on a political basis. That is my concern. 



D,g,tze:Jb.GOOg[e 



172 

I certainly do not object to any new or anybody's ways of trying 
to find answers. I would put that generally under the heading oi re- 
search usii^ a basis of good sound scientific data, the best that is 
available to us. 

Mr. DE LA Gahza. I agree 100 percent with your statement, Mr. 
Randall. As a matter of fact, that is why we introduced this bill. 

Mr. Grandy, I find myself almost living the words that I said 
yesterday. I regret that you were not here. We were hoping to shed 
some light on this problem. When people are polarized, that generates 
only heat, never any light. 

Throughout my life I have considered myself a defender of wildlife. 
My legislative career in the State legislature and here would, I think, 
further substantiate that fact. I do not find myself at all in dis^ree- 
ment with the between-the-lines philosophic^ approach which you 
bring us. 

However, I do suggest, with all due respect, and I get the feeling 
that you have to oppose this bill. Therefore, you had to find ways to 
oppose it. The things you say you want to do are the thii^ that we 
want to do, but you nave taken and dissected the bill on specifics 
and criticized us for not recommending specifics. That is exactly 
what we were trying to get away from. 

We want the research done by the qualified people, I could have 
said in the bill: "Use this specific chemical." That is not what we 
wanted to do. We wanted to have the experts continue research. 

You say 1080 is not good. Mr. Poole says it is. I want someone out 
there that is an expert to continue the research. 

Mr. Gbandt. I do not say that it is not any good, Mr. Chairman. 
I say it does not work. The data show it does not work. 

It works to kill coyotes. There has never been any ailment about 
that. Unfortunately, the data show very clearly that killing more 
coyotes does not help the industry. 

Mr. DE LA Gahza. We agree. However, we are trying to use this 
collar that is selective. I agree with you. I do not want to go kill 
every coyote that is on the range. We do want to get rid of the one 
that becomes a predator by instinct. 

What more selective method can you have than one that gets him 
when he gets his jaws on the neck of the animal? How much more 
selective can you be? 

Mr. Grandy. One of the major problems with 1080 in that regard 
is that it is an acknowledged secondary toxicant. 

Mr. DE LA Gahza. That is not what the experts say. Have you read 
the testimony of Dr. Kun? 

Mr. Grandy. That is what the data say. The opinions of experts 
are, frankly, worth no more than the opimons of laymen unless they 
are backed by the data. 

Mr. DE LA Gahza. They are backed up by data. That is why I am 
sold on the 1080 collar. 

I detest denning. Yet the Secretary has approved it. Yesterday, 
the Assistant Secretary said, "We will shoot the pups." I would place 
them in a zoo. I would give them to a circus. I would do sometning. 

In my area where a coyote is shot on sight, they do not shoot the 
pups. I am in complete disagreement with the Secretary when he says 
that they have no alternative hut to shoot. They are taking the place 
of God when they say "if he is going to die of starvation". 



D,g,tze:Jb.GOOg[e 



173 

I agree with you, but these people have a problem. Saying that it 
is an economic problem that somehow has no solution because Australia 
and New Zealand can sell cheaper here is begging the issue. Of course, 
you do not have all the facts as to why it is they can sell cheaper. 

The only facts I have is that they are able to produce cheaper. 
Conceivably that is because they do not have restrictions. Tliey 
probably have lower w^es. 

Everyone who unders^s the American product undersells it because 
he has lower w^es, no protection for the employee, and no desire to 
be fair and equitable with the profits of their productivity. We do not 
do that in the United States. 

Where in the bill do you find that we provide more money to kill 
massive numbers of coyotes? 

Mr. Grandt. You provide the techniques for UlUng the numbers 
of coyotes which will inherently 

Mr. DE LA Garza. Where in this bill do we provide more money for 
massive kiU'ti g of coyotes? 

Mr. Grandt. You provide the techniques and the direction that 
will allow the massive killing of coyotes. 

If I may just address a couple of points with respect to the collar 

Mr. DE LA Garza. Where do we provide the techniques for massive 
killin g of coyotes? 

Mr. Grandt. The use of 1080 is a mass killing technique. It is 
inherently 

Mr. DE LA Garza. We want to use it selectively in the collar. 

Mr. Grandt. It is inherently uncontrollable when put in the hands 
of ranchers, to which Mr. Randall will testify at some length if you 
like. Indeed, the only problems for which anyone has suggesting using 
a collar, whether it be 1080 or some other nonsecondary toxicant, are 
in farm flock situations. 

The data show conclusively that farm flocks are not the places 
with problems. 

Mr. DE LA Garza. How do you si^gest that you would have massive 
use of 1080? 

Mr. Grandt. I suggest that it would be uncontrollable. It takes 
verv little to kill. You can dismantle a collar. 

The worst part of the whole 1080 problem, the collar or any other 
part of it, is that it provides the industry with some hope that does 
not address the real problem. The problem is labor. If they had sheep- 
herders out there with the sheep, they would not need 1080 collars 
and they would not need strychnine. They would not need thallium. 
They would not need anything. 

Mr. DB LA Garza. Let me go back now. How would you use 1080 
indiscriminately? Where would you put it? If you were an indiscrim- 
inate user, a noncaring individual, and you wanted to kill every 
coyote on your ranch, how would you use 1080? 

Mr. Grandt. If I were going to do it, I would do it the way it has 
always been done. I wouldput out 1080 place baits. I would put out 
1080 this. I would put out 1080 that. 

Mr. DE LA Garza. I do not want this and that. Give me specifics. 

You have been out there, Mr. Randall. How would you use 1080 
if you had no restrictions whatsoever and you wanted to kill every 
predator on your range? 



db.Google 



174 

Mr. Randall. There are several ways to do it. There were always 
carcass baits, the approved type of bait. That was a 1080 solution 
injected into sheep or into horse carcasses that had been butchered. 
Many times jack rabbits, prairie dofis, and other things like that, 
were used and tied to sage bushes. Tliis kind of thing, of course, 
attracts raptors too. 

There are many wavs to use 1080. Referring specifically to the collar, 
I believe this would Be a very limited use ber.ause in the open-range 
type sheep industry, which is a large part of the West, I do not see 
how you could use a toxic collar at all. The theory of it is, if you have 
predation in a pasture, to move the sheep out, put the collar on a 
couple of Judas lambs, leave them in the pasture until the killing 
stops, and then move your sheep back in. This would be unworkable 
in large pasture type situation where you would have to move a lot 
of sheep. It woulcl also be unworkable on the open range. 

Mr. DE LA Garza, Why would you think it would be unworkable? 

Mr. Randall. On the open range the sheep are there. What would 
you do with them? You could not put collars on the whole herd of 
2,000 or 3,000 sheep. 

Mr. DE la Garza. That is agreeable. I do agree with that. 

Do you not think that it works by sending in a group with coUars 
to tm area where you need to send them and you know that predators, 
or at least a coyote predator, might be working? 

Mr. Randall, You would somehow have to separate the Judas 
sheep from the herd in order to get a probability that the coyote would 
kill that sheep rather than 

Mr. DE LA Garza. I am placing you in the position of an expert in 
the field. I understand that is what you have been. 

Everything being equal, if you were to use 1080 — disregard the 
fact that you do not agree with it — which way would you use it? 

Mr. Randall. You mean, provided that 1 wanted to go out. othI 
kill as many coyotes as possible. Is that what you mean? 

Mr. DE la Garza, No, I mean, if you wanted to use 1080 

Mr. Randall. And do it in a very environmentally sound way 

Mr, DE LA Gahza. Ri^ht. 

Mr. Randall, I would lock it in the safe and throw away the 
combination and never open it, 

Mr, DE LA Garza, You did not answer my question. 

Mr. Randall. I do not know of any way^ sir, that I could use it 
and feel responsible that I was doing somethii^ that should be done. 
I do not believe that there is a place for this toxicant in the field. 

Mr. DE LA Garza, Do you know if there is any other substitute? 
I guess we are back to the fact that you want herders — 1,000 of them 
around 1,000 sheep. You want to make a fence of sheepherders. 

Mr. Randall. There are many methods, sir, that can help alleviate 
this problem. Certainly, as many other witnesses have testified, there 
is no panacea that is going to control coyotes, so we have to use a 
whole variety of things. Guard dogs are one things, but it takes a 
certain kind of a person to be able to use a guard dog. 

Mr. DE LA Garza, Where in the bill do you see that we say, "Do 
not use guard dogs"? 

Mr. Randall. I do not see that. We are just sayii^ that this is 
something that ^ould be developed 



D,g,tze:Jb.GOOg[e 



175 

Mr. Geandy. They should be endorsed and set as a priority. 

Mr. DE LA Garza. I feel so badly that you would take the bill apart. 
On page 4 we say, "Use preventive control techniques to manage 
offender predator populations." 

I do not know. I did not want to go naming this one and that one 
to use. We want you to provide input to the Department so that we 
can arrivfr — I agree with you. 

If we could provide for more sheep herders, that would be fine. 

Mr. Ghandt. Preventive control has a meaning in terms of the 
animal damage control program that you may not have intended in 
the bill. 

Why could you not have endorsed, for example, all possible non- 
lethal techniques, includii^ those that have been proven operationally 
in Saskatchewan and other places, such as the use of guard dogs, and 
have provided support for them? 

Mr. DE LA Gakza. You are nitpicking. I did not know what had 
been used in Saskatchewan. That is why I want the research. 

Mr. Randall. Mr. Chairman, I have done an awful lot of preven- 
tive control, and I have killed thousands of coyotes. Most of the work 
I did with Fish and Wildlife was preventive control which is prophy- 
lactic control. That is killing as many animals as you can. 

In the 1971-72 Wyoming winter, we called in three aircraft to Bock 
Springs simply because we had 4 or 5 feet of snow. Under conditions 
like that, all the predators surface. They have no holes and draws to 
hide in. 

You can fly 500 feet in the air and look out a mile away and see a 
coyote. We slaughtered coyotes that winter. 

Mr. DE la Garza. Unlike you, I do not want to slaughter coyotes. 

Mr. Randall. This is what we did 

Mr. DE LA Garza. You are ahead of me there 

Mr. Randall [continuing]. As preventive control. 

I have kepi track of all the loss records and trouble calls. The follow- 
ii^ spring I had just as many or more trouble calls as I had the year 
before, and we had wiped out 50 percent of the coyote population in 
lower Wyoming counties that wint«r. 

Therefore, 1 cannot see a relationship between the number of 
coyotes and the amount of predation. Obviously, if we had one coyote 
in 100 square miles, we would have less predation than if we had 100 
coyotes, but natural fluctuations do not seem to have a whole lot to 
do with the amount of predation. 

Mr. DE LA Garza. Now I find myself in disagreement with you. 
I do not want to have massive killing of coyotes. I do not want to 
slaughter coyotes. I only want to get the 1, or 2, or 3 out of the 
100 that become predators. That is why I am sold, with what little 
scientific knowledge I have and specific data, on the collar and 1080. 

I find myself in disagreement with you now. 

I am going to wind up being by myself and in disagreement with 
everyone. 

Mr. Grandt. I was in disagreement with Mr. Randall too, when 
he worked for the Fish and Wildlife Service and he did all these things. 

I think our point is that we should address — and we should not 
shrink from addressing — the real problems. The real problems are 



D,g,tze:Jb.GOOg[e 



176 

that there is an inadequate labor supply. Once we have dealt with 
that problem and once we can invoke some nonlethal controls that 
have worked and are beinR used operationally — although you may 
not have known they were oeing used before we came, you certainly 
know it now — if we still have a predator problem we can come back 
and try some other things. 
There is no reason to kill American wildlife if we do not have to. 
Mr. DB LA Gahza, No one wants to kill wildlife. I ^;ree with you. 
I am probably more of a defender, with all due respect, than most 
members of your organization are. 

It is simply that we have a problem. I accept your honest offer to 
work with us. I think we can work together. 

You see, I have been exposed to massive scientific data that I have 
no personal way of refuting. The figures are there. The research is 
there. I have spoken to the scientists. They are certainly knowledge- 
able and respected in their fields. 

My people say that generally there is a problem. The question is: 
How do we solve that problem? I am an advocate of legislation as the 
art of the possible. I do not believe in creating a massive hill because 
it sounds good which makes you feel better even though you have not 
done anything. I do not operate that way, nor do members of this 
subcommittee. 
We are looking for a solution. 

I guess there is a way under CETA, or other programs, to provide 
for more sheepherders. In my area you cannot get them. You have to 
get them from other countries — Mexico or Spain, sometimes Germany 
or Austria — but the Immigration Department will not let them in, 

They have told me, "Tell your people not even to apply. We will 
not let them in." 

I can personally attest to the fact that the social pr<^ams of this 
country are such that a fellow can live more comfortably without 
working than going out and working for 2, 4, or 6 weeks out on the 
rai^e. 

You could not give us any information on pay and I do not know 
where we would be on that, but 1 do disagree with ^our economic 
analysis. You said that once we get to the economic pomt of no return 
then we can foreet the industry, just dump it out of the window. We 

have a responsibility 

Mr. Grandt. I am not saying that. I suggest that you have just 
outlined a few problems that this committee would be able to addrass. 
We would be happy to help you and I am sure the industry would be 
happy to help you m terms of getting the wages right, how to provide 

the right incentives, and how to get people in here 

Mr. DE LA Garza. The statement from you is that you have some 
technical objections to the way the bill is written. You really have no 
objection to the thrust of what we are trying to do. Is that risht? 
Mr. Grandt. I stand with my statement. We object to the bill on 
many grounds, but primarily because we feel it simply does the wrong 
things at the wrong time. 
Mr. DE LA Gabza. I respect that opinion of yours. Your philosophical 

viewpoint is that there is a problem that has to be addreaaea 

Mr. Grandt. The problem is with the industry. 
Mr. DE LA Garza [continuing]. And you are willing to woA with 
us in addressing that problem. 



D,g,tze:Jb.GOOg[e 



177 

Mr. Ghandy. Absolutely. 

Mr. DE LA Garza. I thiiik, with good faith and some diligent woi^ — 
certainly cannot escape the fact that we need research. That is one of 
the areas in which we provided for the continuation of research on 
lOSO and "applied field research relating to nonlethal animal damage 
control techniques and the effectiveness of economically feasible 
husbandry practices in reducing livestock losses." 

There our bill says what you said, 

Mr. Ghandt, That is right. I think we could probably all agree 
on that if you knocked out the rest of the bill. 

Mr. DB la Gahza. We do agree on that part. 

On 1080 we emphasize "selective and environmentally preferred 
lethal and nonlethal toxicants." You say, "no toxicants at all." 

Mr. Ghandt. We mean no secondary toxicants. No toxicants should 
be used which are not necessary. Our view on whether or not something 
was necessary would be formed after you had an adequate labor 
supply and had exhausted some nonlethal control techniques. Then 
we could make a decision on that. 

Mr. DG LA Garza. I agree nith you on that. Perhaps if we had a 
little more time, we would wind up writing a good bill here. I guess I 
mean to say, a better bill. I think it is a good oill. 

I do not want a toxicant that has secondary eSects and you do not 
either but if there were one that does not have secondary effects and 
could be used selectively, that is what I am trying to get at and that is 
what you are trying to get at. 

Mr, Ghandt. That is what we are trying to get at. 

Mr. DE LA Garza. I think we can work something out. 

Mr. Grandt. We are also trying to get at some other problems that 
I think we outhned in detail. I would hope this committee would want 
to get at them as well. 

Mr. DG LA Garza. Do you mean, related to this problem? 

Mr. Ghandt, I mean, related to labor and implementing the non- 
lethal alternatives which have already been proven and i^ed opera- 
tionally in other areas. 

Mr. DB LA Garza, I am going to instruct the staff to try to get some 
more information on the labor situation. 

The testimony which we have had here from landowners and the 
people who run sheep and goats said that it is very difficult. Perhaps 
we might check with labor and work on that. 

That is a method, not the method. 

Mr. BandaU, what do you say? Con every loss to a predator be 
avoided by having a sheepherder? 

Mr. Randall. It will depend a great deal on the sheepherder. I do 
not think every loss could ever he avoided but certainly they could be 
cut down to an acceptable level. 

Mr. D£ LA Garza. In other words, it would depend on whether or not 
he is a good one. 

Mr. Randall. It takes some experiencfl. Sheepherding is not some- 
thing in which you just go out with a staff and walk around. It is very 
intricate. They nave to be very dedicated. 

Mr. DE la Garza. You have to inherit the art from your father who 
is a sheepherder. 

Mr. Randall. That would be desirable, but I believe in a good 
training program we coiild turn out some very good sheepherders. 



D,g,tze:Jb.GOOg[e 



178 

Mr. DE LA Garza. That is why you bni^ the Basques from Spain, 
who are third or fourth |;eneration sheepherders. You find me a second 
generation sheepherder in Wyoming and I will buy him. [Laughter.] 

Mr. Grandt. We used to have some wonderful old Mexican sheep- 
herders. 

Mr. DB LA Garza. We do not anymore. Immigration will not let 
them in. 

Mr. Grandt. I do not think you nan buy and sell people. 

Mr. HE LA Garza. You are right. I agree with you. 

It is something you have to feel, something bom in you. You have 
to love the sheep. You have to love the range. You have to feel the 
vibrations of that grass on your feet when you walk out there. 

Mr, Randall. It sounds like you have been there. 

Mr. DE la Garza. I have, sir. There are no more of those people. I 
do not think you can train them in the Labor Department traming 
programs. 

Mr. Randall. I think we could provide some incentives for trainii^. 
This has been a completely neglected area. We have never tried. 

We have some sheepshearing schools and things like that 

Mr. DE LA Garza. Do you not want us to bring the sheepshearers 
from Australia? 

Mr. Grandy. Who said that? 

Mr, DE LA Garza. A witness yesterday said it. 

Mr. Grandt. Those people I keep hearing about who are beii^ laid 
off are going to be willing to shear about anything. 

Mr. Wampler. The law of the land is that they cannot come in. 

Mr. Chairman, may I make one brief observation, even though I 
have taken way too much time with the witnesses? 

Mr. DE LA Garza. I think I have too. 

Mr, Wampler. Let me say, in all sincerity, this committee finds 
itself constantly caught up in the throes of different legitimate concerns 
and interest groups. You know, we have people come before this com- 
mittee from time to time who honestly believe that our agricultural 
pohcy should be a return to organic agriculture. They believe it for 
a variety of reasons. 

There are many people who honestly believe that we should not use 
^^icultural chemicals or pesticides. I am concerned about what the 

Eersistent and continued use of pesticides will do to the environment, 
ut I would prefer to have the scientists tell me what effect they are 
having rather than people who speak with deep emotion on the mattw. 

I suppose it would be possible for us to remand the use of all pes- 
ticides and all chemicals and return to organic agriculture, but if we 
were to do that, who would make the decision as to what millions 
would starve here or there — because that would be the alternative. 

Secretary Butz used to use this illustration. He said that when he 
was a boy on their family farm in Indiana, among his chores eveiy 
summer was to take a wooden paddle and go out and swat potato 
bugs. If he did not do that they would devour the crop. 

Now you can use a pesticide and control the potato bug and free 
that person to do something else. What has happened in tne i^iicul- 
tural economy of this country is that fewer ana fewer people are pro- 
ducing more and more. I submit to you that if every sector of our 
economy had done as much to improve its production as agrieultun 



D,g,tze:Jb.GOOg[e 



178 

has, inilation would not be the rampant problem that it is today. I 
am not saying that it would not be with us. 

What we have to do here is to get some semblance of balance be- 
tween desirable and achievable economic goals on one hand and then 
adequate concern for the environment on the other. Here is a classical 
example of these kinds of confrontations and clashes. 

These great questions of public policy do not have easy answers, 
but we do have an obligation to weigh Iroth sides of the equation. 

Your presence here and your testimony certainly give us a valid 
point of view to which we will give adequate consideration. I join 
with the chairman in the hope that you will continue to work with us 
in finding areas of agreement and hopefully to eliminate areas where 
there is disagreement. 

I thank you very much. 

Mr. DB LA Garza. Thank you very much. 

We are informed that the full committee that is meeting next door 
needs two more members for a quorum. 

We have been advised, as well, that Commissioner Douglass of 
West Virginia has arrived. 

If you will stretch a minute and bear with us, we will stand in recess 
for about 5 minutes. Congress is also in session and we have a recorded 
vote, so the recess may continue for about 15 minutes. 

[Recess taken.) 

Mr. DE LA Garza. The subcommittee will be in order. 

We welcome you, Commissioner Douglass. Without objection, your 
full statement will appear in the record if you care to summarize or 
quote from it. We would appreciate your doii^ that. 



D,g,tze:Jb.GOOg[e 



irdl,. 



of th« 



Mgt Centra 



Pronfii. U.S. Fi'h ml HildlitB Strviee. Th<» iotMmmaf cviliutcl the SM 

■ ffccciva, nUtivglj snhintul Co Che environ 

I (or » adaquice predicai lutag* auugeiHat proiru. In 

, to the AaiLitmc Sectecarj. Flab, and HiUlife and 

enwalt, Director, D.S. Fiah and Wildlife Service, >1* 



aai«BtiallT andc 

noveabar B, I9T9, 
Hi Id 11 fa Service 
datiooa st vildlifi 
Fabruary IS, 19B0, 



of Inteiior, haMier, iaiuad a palicj d 
to hem predatoT control Hill be conduct 
Che fuCuTe Chac ia eootrarr to ch* profe 
aanagaii and researcti Inforaatian. In a 

Interior Andru.' Poller SCaleMiit . 



Bed of 16 o 






baaed on raaeareb data and they be 



ideal of the nan polic 
c vill not pToride adei; 



iCacaa hav* had their backa ihoved aiainaC the wall. Thar ar* literally faced 
vich ■ itrugtle foT aurrival. He aerlouilr doubt if the Congreaa intended the 
DaparnanC of Intalior, Fiah and Wildlife Service, to interpret cheir amdata 

elsnal TMoaBandatleaa , aiparinc* and teeoereta tindinta, and mmU in all 
FTababitlC7 MStlaM M iayaet to •dveraaly and aeverely opoa thee* troopa. 



lb* Otalta*^- ■>»^ spaa tU> oral fUlmmj balon job coday, 



aMtltVMl Ir 

7 



•dUin' "Ith th» reapcBiiit.; Ut» to EOTExal fcal- 
f caatnl *ct of 193' «■ kl^lf 

t •t osw. •■ -^ "*•*' i"*"^ 

. LB. «TUimaU 




i 



Do,i,.ab,GoOgle 



ulu caetTol und r«»arch ■ jatoC efforc 
ili((*T*nt |»I* tnA diffamc pbiloiophie 



i DSQ&, Ha do luw- 



. 671S applj [Q Fadsral land! a* oell a* gti 

liaa 14i Scrilca the pariod ud add the word.' 



>Catiu lituacian la Iha MCCan atataa, eootrsl oUb all aethoda tnclud- 
nicanta aad an all laodi ia aaautial. Ccnttol affDrca at chia tlM, 
.ally vith toiclcaBCa, ata liiaitad oa fadacal Unda bacauaa of Bxacutlva 
116*3 ud a iwEica t? Cb* KnTiroBMaEal ProtacCioo tfaej ia tbc Fsdara 
:ar (r.l. 71-1). *a(iai> abould ba takae to Tasciiul thaia diractivaa Co 



Buld Ilk* to aotalc lot tha taeart eopUa at taammf ibat r«UiB 
• CaoCiata cha iaaua* I bave praicntad tada;. They arai 



tmtj JudTua froa Di. Hillin p. 8ce(itaes(, 
■ipniaini cha policy of iUDA on (ba nw ADC 



aolucion bjr USM aupportiat Che aiciwEiiaucal ule of COKpauad 
, or tbac Cha Fadaral lovamaanC axpeod cha nauiaaTT Ciuda Co 
cs pEsdacor Isaag* ta a aecapcabla lent b; ach« aeChada, or 
sniata praducsia foT pradater cauaed loaaaa abava Che laTola of 



1. Joint icaCnaBC on tin Psdeiil roll ragardini 
eancrol. Endoriad byi NUIU, Matlaoal Cactla 
Kaciansl Uool GroHara' Aaaociatioo. 



D,g,tze:Jb.GOOg[e 



7(fe TUa^-c^ ;1iMi<ttOut t{ Saut "Dc/UMau^Oi ^ TiyiiadCm 



s. B, GnuU, Extmivr Sterrary 



D««b« II, 1S79 



HaDir 






1 D 


AndB. 


Seen 

Dnic 


d gta 


»■ 


D.|M 




oHi 


J of 




Sac 






nston 


" 


C. 


20140 


Dur 


E«H 


t«ry Andnial 



mtad to u ».»■! of jbout eight 
the lanb crop did K« 4uid one-hil 

mieri nore tbaii S3T ■iHioo The! 

m in ntah and Ujcnnc. 






iallr todoTHd ■ cGnti»«<, 



D,g,tze:Jb.GOOg[e 



B affective progTM ta eoatrol 

r tara, prcraitlve control 

c ■icuaticmi where uneccepcably hifh 
nell of loiies have been dQcimenced during the preceding 11 
nicfa*. Tb* policy alio itatei Chet In the long tern, the goal 
bould ba to ndniniie aad phase out the uae of lethal prevenciva 
DBtTole, includLDg ereatioD of buffer lODei and that correctiva 
DDtrol utiliiinc OOD-Iathal, nDB-cepclva BMhod* ahould ba 

It ahould ba ooted that aa onaeeeptably high lovcl of loe* bai not 



bean dafined. llao the a 



(epiog a 



ribed. Tbo refex^ence documents indicete 
theca are oo Tion-lethal leehaique. evail.ble that will effectivalj 
reduce losies on a bcoad geographic icale. Until they are de- 
valopad and teiced, protection ahould ba provided for livestock 
producara. The variety of geogtaphic loeatiooa of ranch operationa 
throughoat the wait thus reijuires the uae of both lethal and 
noD-Iathal Methoda in a control pcogc^. 



Dnti 


1, and 


1£ 


noir-1 


.athal, 


, eorreecii 


'e control 


•echod* an 


t del 


«lop«< 


and 


teated 






should not 


: be place. 


d on the ua. 


t of 


the el 


fact 








menta' 


lly aefa at 


sthoda pre: 


lantly utilited 


for 


aoim 


al dam 


■ge 


cent. 


rol. ■ 


rhe praetic 


:aa of deDning and aei 


rial 


ahoot- 



the Federal gc 


.vernment 


. Thi. F 


iredaci< 


le— so< 


liim mmofluoroa 


icetate 






"loao— h 


las bee. 


1 undei 


r a ban by Cba EnvitOD- 




■ion Ageni 




19T2 




ilista vho have 


worked 


on the problen 




rinced t(i 


laC defi 




? experinenCB wa 




onstr.te chat 


lOBO cen 


ba, and 


in fact 




.een, used effec 


tively 


in a eontroU. 


■.i manner 


.gainat 


coyote) 


1 with' 




other 


■peeiae nr him 


uans and < 


«th litt 




srse environiieat 




iapact. Sound 








Incipl. 


!S alao iodicat, 


■ that 


the survival, c 


,t Che CO- 




.lea ici 


lelf w. 


luld not be thre 




The end result 


, would s- 


imply be 




^ion for livestock vhe 


■a Jind 




J. Pres 


Ldential 






Executive Order 


11643 


of Tebruary S 


19?2, ». 




by Ell 




! Order 11870 ol 


: July 


18, 1975, would permc 




lerimenl 


:» end 


•ventual aperat 




uae to ba cond 


lucted by 


federal 


personnel on 


federal lands 


KASDA 



other aatbad* 

above Um leveli of 19SS 

Dm livealoek induacry throughout tb* Vaat will ba Mvaraly iapaetad by Um 
an policy diractive if it ta to ba iaplaamtod to tka lattar. On behalf aC 
USDAi I lincerely urga you to reeosaidat your deeiiion io view of Iha evid- 
enea, the profcaaional reeoBBeodationa, and the advecac affects that a piograa 
conduetad under tho new policy maid have oo the liveitoclc induatry, 

Sia< 



'CniTaa'p. Stephen* / 



D,g,tze:Jb.GOOg[e 



SOaJECT OF RESOLUT30W PREDATOR COMTRCg. 

ORIGIN OF BESOLUTICat WftSDA 

DATE OF ORIGI N July 23. 1979 ^^'"*' 



Millions of acres of grazing lands, some of which ara undac -tha 
jui-iadiction of the Departaient of the Interior and the Departnient of 
Agriculture, are infested with preflatory anijnals. Aa a result ther«- 
□f, it is not economically feasible for livestock producers to graze 
their livestock thereon, and food and fiber are being destroyed. 
These grazing lands could be effectively used, and great financial 
losses could be mitigated it those livestock producers were provided 
an effective program so as to control sucti predators. 

The Act of March 2, 1931 directs the Secretary of Interior to 
control predators, and the federal government has chosen control ^ 
tnathods and the level of control to be used under the Act of March 
3, 1931; and produce-s' losses depend upon the federal government's 
choice of control methods and the level of said control effort. i 

Livestock producers need a quick-killing, species-specific control 
ir.ethod which stops predators. There is compelling evidence that such 
an effective predacide exists that could be used effectively with the 
cooperation of the federal government. This predacide — sodium 
f luoroacetate , mare commonly known as 'loao" — has been under a bau 
by the Environmental Protection Agency since 1972. Specialists who 
have worked on the problem are convinced that definitive experiments 
would demonstrate that 1080 can be used effectively in a controlled 
' ;:er.r.e= against predators without endangering other species or h'jmans 
and with little or no adverse environmental impact. Presidential * 
amendment of Executive Order 11643 of February G, 1972, as amended by 
'Executive Order 11B70 of July IB, 1975, would permit such experiments 
to be conducted by federal personnel on federal lands. 

ACTION TAKEN BY MASDA STAHDISG COMMITTEE ^ ; 

ACTION TAKEN BX HASDA fiEEOLUTIOH COMMITTEE 

ACTION TAKEN BY NAEDA 



D,g,tze:Jb.GOOg[e 



BE IT RESOLVED, that the National Association of State Depart- 
ments of Agriculture, meeting at Hinston-Saleia, North Carolina, on 
Septetnber 23-27, 1979, urges Presidential amendment of EO 11S43 to 
permit experiments in the use of lOBO in a controlled manner, with 
due attention paid to safeguarding nonpredator species and the en- 
vironment so that livestock producers may be provided in the near 
future with an effective tool to protect their livelihood, or in 
the event this is not possible, that the fefleral government expend 
tdiatever funds are necessary to reduce predator losses to an accept- 
able level, whatever the cost, or compensate producers for predator 
caused losses above the levels of 1955. 



D,B,i..ab,Google 



188 

Mr. Wamplbb. I want to add my word of welcome to Commisuoner 
Douglass to the committee. He has beeo before us on a number of 
occflsioQs. He is an outstanding cominissioaer of E^riculture in a 
sister State of my State of Vii^ima, which once was a part of Vii^inia, 
but that is a period in history that we will not go into this morning. 
I do appreciate ^our fine statement. As you know, yesterday we 
heard from Commissioner Brown of Texas. He is a member of your 
oi%anizatioD and gave us some specific recommendations. 

1 have always found, Mr. Chainnan, that the National Association 
of State Departments of Agriculture, in many respects, has a better 
perspective on the regulatory function than perhaps we, here in 
Wasnington, have. In large measure they are tne ones who have to 
implement, or certainly coordinate the implementation of, many of 
the laws that Congress passes. 

So, I think it is always appropriate that we hear from them and 
seriously consider their recommendations and take to heart their 
observations. 
Again, we do appreciate your appearance here this morning. 
Mr. Douglass. Thank you, Mr. Wampler. 
Mr. DE LA Oarza. Thank you, sir. 

We recently lost a distinguished, dear colleague of ours from West 
Vii^inia, who was a great friend of agriculture, John Slack. To what- 
ever extent you can, I wish you would bring our sympathies back to 
the people of West Virginia and the people of his distnct. 

Mr. DonoLASs. Mr. Chairman, I will certainly do that. He was a 
very good personal friend of mine. He was a Congressman from my 
own congressional district. We know his wife, son, and family well. 
I will convey your message. 

Mr. DE LA Garza. If you will do that, we would appreciate it. He 
was truly a public servant of national and international renown and 
was very helpful in the endeavors he undertook as a Member of Con- 
gress. \ 
Mr. DouOLASB. Thank you, sir. 
Mr. DB LA Garza. Thank you. 

Our next witness is Ms. Marguerite Perkins of the Humane Society 
of the United States. 

Ms, Perkins, we welcome you and would be very happy to hear 
from you at this time. 

STATEUKNT OF IIAKQ-UESITE PERKINS, LEGISLATIVE ASSOOIAIE, 
HUUAITE SOCIETT OF THE TTNITEI) STATES 

Ms. Perkins. Good morning. Chairman de la Garza and members 
of the subcommittee. 

I appreciate this opportunity to express my oi^anization's views at 
this time. 

I am Mai^erite Perkins. I am legislative associate with the Humane 
Society of the United States. My educational background is in animal 
behavior and political science. 

For the last 20 years or more I have traveled with my father. Dr. 
Marlin Perkins, and participated in game and wildlife management 
as well as predator control activities m South America, East Africa, 
South Africa, and Australia. 



D,g,tze:Jb.GOOg[e 



The HSUS is a national animal welfare organization with a con- 
stituency of more than 150,000. We have been mvolved since the mid- 
1960's in working to make the animal damage control pn^ram humane 
and selective. 

During the last 2 years we have been involved in every part of the 
public decisionmaking process which the Department oi the Interior 
has conducted on this controversial issue. The HSUS is in support of 
the secretarial policy decision which was finally made late last year. 

Although there are parts of it with which we do not agree — aerial 
shooting, use of steel traps, and preventative control — we feel that it 
is an untested policy which, if implemented correctly, will eventually 
result in the selective and humane program our membership wants to 
see. 

For this reason, I am appearing in opposition to H.B. 6725. 

The sections of the bill which we could support— cooperation 
between the U.S. Departments of the Interior and A£;riculture; em- 
phasis on field research into selective, nonlethal, ana humane toxi- 
cants and traps; and further study into the feasibility of husbandry 
techniques — are all embodied in the Secretary's current policy. 
Therefore, we feel those parts of the bill are repetitive and unneces- 
sary. 

The HSUS was a party to the original lawsuit which resulted in 
the ban of sodium monofluoroacetate or 1080 8 years ago. Our position 
has not changed in that time. For this reason, even if we did not feel 
that the body of the bill is unnecessary, we would have to oppose it. 

Not only has our position not changed; 1080 has not chan^d. It 
remains a lethal toxicant for which there is no antidote. Its chemical 
stability is still one which resists breakdown and therefore can con- 
taminate water tables. When used in a baited situation, it is non- 
selective and has secondary poisoning effects. 

Our main objection to 1080 is one which will not change. 

This toxicant causes a lingering and painful death. I quote from a 
study done in New Zealand in 1977 and 1978 on dogs which are 
physiologically quite similar to coyotes: 

The effects of 1080 poisoning in the dog are heralded, 4 to 5 hours after inges- 
tion, by cantinuat barking and howling for h few minutes. The dag becomEB 
overactive, and behaves as if terrified, but appears to be unaware of its surround- 
ings. There are tonic convulsions (sustained muscle contractions) followed by 
running movements. Vomiting is common in Geld posioning cases. All clinical 
signs may disappear completely and the dog appear normal until it finally suc- 
cumbs to the toxic effect on its CNS. Death is typically the result of respiratory 
paralysis. Death is never primarily cardiac in origin. The heart generally slows 
during the convulsive seizures but often continues beating for some time after 
respiration fails. 

We cannot understand the fevered advocacy for 1080 use 8 years 
after its ban. According to the Cain report for the Council on En- 
vironmental (Quality in 1971, there is great ambiguity in loss trends 
during the period from 1950 to 1970 when 1080 was in widespread use. 

I quote: 

In two of four States (Idaho and Utah), the mean annual loss in the postrlOSO 
era (1950-70) is slightly higher than, in the preceeding 10 years; in Wyoming it 
is higher and in Colorado it is essentially the same. 

I think Dr. Grandy was quoting these figures earlier. 



db.Google 



Explaaations offered by the Cain study for this ambiguity include: 
(2) The true level of sheep losses to predators ts so low thftt cutting it in lulf 
does not materially cliange the level of total losses; (3) The predatory and non- 
predatory losses are somewhat compensatory. For example, coyotes may often 
take sheep which would die anyway due to sickness, malnutrition, or other causes. 
The result is the same with or without predation toss. There is almost cettainly 
some de^e of competing probability among the various causes of loss. Obviously, 
some animals saved from one mortality agent will die from another. 

Weighing the extremely negative properties of this toxicant against 
its unproven ability after 20 years oi use to significantly effect lossee, 
in our opinion, confirms Secretary Andrus' decision to reaffirm Presi- 
dential policy and to ban further 1080 research. 

We have recently seen some 1978 data from the Denver Wildlife 
Research Center and from Alberta, Canada, on the field testing 
effectiveness of 1080 collars. We do feel that the results of this testing 
are encouraging. It appears to be an effective control mefliod. How- 
ever, we do support the necessary humane selective methods employed 
in conjunction with adequate husbandry techniques. 

Although we may in the future consider support for a toxic collar, 
such support will only occur when said collar contains a humane and 
fast-actii^ toxicant, based on the inhumane death which can take up 
to 10 hours or more from 1080 poisoning. However, I do understand 
that 1080, used in a toxic collar situation, does not have secondary 
toxicant effects so that environmental hazard would be withdrawn. 
However, we do feel that the inhumane properties of the toxicant 
should forbid its use. 

We would prefer to see field research on the use of collars containing 
sublethal taste aversive agents. Research with taste aversive agents 
in the field indicates that coyotes demonstrate learned behavior 
negative to sheep after aversive experiences. 

We can understand the frustration a rancher with small or laige 
holdings must feel when he loses livestock durii^ open-range grazing 
periods. 

However, we believe that more responsibility must be taken for 
sheep turned out onto open ranges. The HSUS position has always 
included reducing or suhdividii^ individual herd sizes and employing 
shepherds and guard dogs like the Romondor to discourage predators. 

We think that more oversight should occur on the range including 
night corralling in areas of traditionally high loss rates and lambing 
sheds for the ewes, and that more veterinary care should be available. 

I, personally, grew up ivith veterinarians and have witnessed tiie 
birth of many species of sheep, both domestic and wild. CounUeas 
complications can and do occur before, during, and after birth which, 
if left unattended, can resiJt in the death of both lamb and mother, Oi 
course, during lambing the ewe and lamb are highly susceptible to 
predation. 

Increasing amounts of data, resulting from careful predator-^rey 
studies in the field, illustrate that the condition of the prey determuus 
to a large extent if it is in fact preyed upon. This is a natural system of 
checks and balances designed, if I may use that term, to insure sur- 
vival of the fittest, genetically speaking. The prey species must be 
either swift or stroi^, but above all, alert. 



D,g,tze:Jb.GOOg[e 



10 



191 

The sheep that are released on open Federal rangelands are the 
genetic result of thousands of years of selective breeding for docility, 
^epherds have always been with the flocks to guard against predators 
night and day. 

Industry spokesmen have countered any pro-shepherd arguments 
with the complaint that you just cannot get good help anymore. 
Industry-prepared cost figures for labor-intensive methods have also 
been used as ai^umeats. 

We believe that any sound husbandry program must include 
shepherds and d<^ and 5u^2:est that if costs are in fact as prohibitive 
as ranchers say, that the possibility of a CETA trainii^ program for 
shepherds be explored, Oi course, this suggestion could be rendered 
null and void by the budget balancing that is going on right now which 
threatens to gut most of the CETA program. 

The quality of the range itself also effects losses. Overgrazii^ by 
domestic livestock and/or rodenticide programs can reduce tne natural 
prey of coyotes, in particular, to such an extent that the only available 
:ooa source is any sheep who happens to be nearby. 

For this reason we agree with Secretary Andrus' decision to set up 
an interagency working group. Often the USDA's rodenticide program 
is self-defeating. 

As early as 1937, the beneficial link between coyotes and rodents 
was recognized. Charles T. Vorhies, a range biologist, said: 



cftted to preserve hawkn and owls to do their work, they, witli other predators, 
might go far towards solving the rodent problem. 
(Cain Report, 1971). 

In closing, we would like to reiterate that we realize the products 
derived from livestock are valuable national resources and we know 
that in some cases there are real problems with wild predators which 
need to be alleviated. 

We support the intent of Secretary Andrus' policy and in the future 
will work willingly with all affected parties in developing a pn^ram 
which encourages sound range management for the oe^fit of Doth 
indigenous wildlife populations and livestock. 

Thank you. 

Mr, DB LA Garza. Thank you very much. 

Mr. Wampler? 

Mr. Wampler, Thank you, Mr. Chairman. 

I want to commend you on your very fine statement and ^our 

Eresentation here this morning. I assume that you heard Commissioner 
>ouglass who preceded you. 
On page 4 of his statemoit he said : 

Id a document dated February 15, 19S0, the Western Regional Coordinating 
Committee submitted a response to Secretary of the Interior Andrua' policy 
statement. This committee is composed of 26 of the leading predator control and 
research scientists in the United States. Their response is very critical of the neW 
policy announced by Secretary Andrus. They believe it to be a political policy 
rather than one based on research data. They believe it will not provide adequate 
protection to livestock. 

Are you familiar with that study? 

Ms. Ferkins. No; I am not familiar with that studj. 

Mr. Wamplbb. That is a pretty serious allegation, is it not 



D,g,tze:Jb.GOOg[e 



192 

Ms. Perkins. It certainly is. 

Mr. Wamplbr [continuii^]. When it comes from 26 research scien- 
tists. I do not know who they are but I would assume they are scien- 
tists who 

Ms. Perkins. I think — if you will permit me — that one of the 
problems we have with this issue is that there is such a polarization of 
opinion. There is certainly data supporting both sides. It is a very 
tricky problem. I do not envy you your decisionmaking capacity here. 

I uunk that the best way tor us to try to alleviate it is for us to 
stop taking unbending postures and try to negotiate something for 
the benefit of everybody. 

Mr. Wampler. I could not agree with you more. I hope that will 
be the atmosphere in which we will try to move this legislation. 

I just want to say that I had no strong preconceived notions on this 
question when these hearings began. Some of the testimony I heard 
yesterday, particularly as it relates to the Andrus decision, made me 
feel incredulous that here was a man charged with the responsibility 
of making public policy at the highest level in the executive branch 
who went against the professionals in his own department. Apparently, 
his advisory committee split on their vote, which would suggest that 
there was a genuine division of opinion. 

Ms. Perkins. It is a very emotional issue. 

Mr. Wampler. It leads me to believe that it was a basically political 
decision. Whether it is right or wrong, it is not based on sound scien- 
tific methodology and data. 

Ms. Perkins. Are you talking about the 1080 ban? 

Mr. Wampler. Yes, primarily. 

Ms. Perkins. I do believe that that was based on scientific research 
that is available. As we have said, outside of the toxic collar research, 
the only research available are the loss rates for the years when 1080 
was in use. As Dr. Grandy said and as I have reiterated, that data 
gives no evidence that 1080 was effective in reducing losses. 

There are so many variables in losses. So many things can happen 
to a sheep, or goat, or cow out on the range that are not necessarily 
prey related. Often prey are just behaving m a scavenger's role when 
they are found on a carcass. 

Mr. Wampler. I can appreciate that, the difficulty of determining 
from statistics what the actual cause of the death was. I can only 
surmise that the criticism rendered by the committee, to which Com- 
missioner Douglas referred, does include criticism of the banning of 
any further research on 1080. It does not state that specifically. It 
relates to the total policy and that is one of its mora controTersial 
aspects. 

I appreciate your expression of desire to see if we cannot find areas 
of agreement. That is what I am concerned about. 

Ms. Perkins. As I said, my organization would consider support 
for a toxic collar if it contained a toxicant which was environmentallv 
safer than 1080 has seemed to have been and also provided a quick 
and humane death. 

Death from 1080 is death by strai^ulation. The nervous system of 
the animal is paralyzed. It is very slow and painful. 

Also, it has emetic effects which means that the nnimn.] wiU vomit. 
This can cause secondary poisoning, which could just be one ude e£F«ct 
to the use of the 1080 collar. 



D,g,tze:Jb.GOOg[e 



I just do not understand why this toxicant is being held up as the 
only thing that will serve. In the last 8 years research comd have 
been going on, on other toxicants, but it seems that the hope that 
this toxicant would be reauthorized has kept other research from 
going forward. 

Mr. Wampler. This has been a problem, let me assure you, in the 
Department of Agriculture and other agencies. That is that our re- 
search budgets have been taking cuts through the years. We should be 
devoting more of our research resources to problems of the environ- 

Ms. Perkins. ADC got $2 million 2 years ago from Agriculture 
specifically for research. It sort of evaporated into the program, which 
was brought out in the audit that was done by the SoUcitor's Office. 

Mr. Wamplbb. I am a strong advocate of increased research to see 
if we can find the answers and alternatives that are environmentally 
acceptable. I assure you that I will work in that capacity as best I 
know how. 

I sometimes feel as though I have been a voice in the wilderness, but 
maybe we are getting more support now for havii^ more meaningful 
research that will address these legitimate concerns that I think you 
and I share, 

Ms, Perkins. As you discussed before, it is really not practical to 
put a toxic collar on every sheep that is out there. Certainly the whole 
problem must be addressed of managing the sheep populations. 

I think that we do not necessarily need 1,000 shepherds for 1,000 
sheep. 

Mr, Wampler. You have been a very effective and gracious witness. 
I appreciate your appearance. 

Ms. Perkins. Thank you very much. 

Mr. DE LA Gahza, I, too, want to thank you for agreeing with me 
that the possible use of the collar is something on which we must do 
further research. 

The basic problem is that you want a more toxic substance that 
will be instantaneously lethal. Your problem with 1980 is that it is not. 

We have people on the other side who do not want an instantane- 
ously lethal substance because it might have side effects, or be non- 
degradable, or whatever 

Ms. Perkins. It would have to be a nonsecondaiy toxicajit, but 
the lethal dose factor of the toxicant is meaningless if there is no 
antidote available. There is no antidote for 1080, Any other toxicant 
that might be registered and used experimentally would certainly have 
to have an antidote developed. 

Mr, DB LA Garza. This is where proper use in handling comes in. 
Its use in the toxic collar would be such that if everythii^ else were to 
work right there would be no need for it. 

For the positive approach you have taken and your agreement, in 
part, with us, we are appreciative. 

Let me ask you this. Do you agree unqualifiedly with the decisions 
of Secretary Andnis? 

Ms. Perkins. No; I do not. 

Mr. DE LA Gabza. Do you have any differences with any parts of 
the policy? 



D,g,tze:Jb.GOOg[e 



194 

Ms. Pbekikb. Yes. We would prefer to see preventative coatrots. 
stopped. We do not think it works. It has not demoostrated that it 
works. 

We want selective predator control. 

We understand that there are problems, that there are areas, 
particularly in Colorado, where losses are a real problem. In titose 
cases, selective control measures, wherein known offenders are taken, 
would be preferable. 

Not all coyotes will go for sheep. 

Mr. DB LA Qarza. That is right. We a^ree on that. 

What is your organization's position with regard to the Secretary's 
decision on denning? 

Ms. Pebkins. We approve of that, I think it was a good thing to do. 
When we are trying to work out solutions to problems, it is a good 
idea to defuse some of the most controversial elements of them. 

Dennii^ was a very controversial thing. It was done very cruelly. 
I do not Imow if you know how they uaed to perform it. 

The loophole which you have been questionii^, I think, says that 
pups could be taken if it were known that they were starving to death. 
That is a situation in which It is knoi^-u that a lactating female is 
taken in a predator control situation. They would know that there 
were pups somewhere and would go and dispatch them. 

I do not think zoos would want to take a coyote. They are not an 
endai^ered species. Zoos are not famous for their canid displays. 
I know quite a lot about zoos and I do not think that would be anv 
outlet for them. I think it is probably better to humanely dispatch 
them. 

Mr. DE LA Garza. I do not agree with you. How can you shoot a 
little pup because somebody says they have no place to put themT 
They could at least make an effort, 

Ms. Perkins. If they could be relocated, that would be fine, but 
then I suppose they would also have to go through raising them. 
The problem \vith raising a canid is that it will socialize itself to 
humans and it will not be wild. 

Also, canids have to be taught by their parents how to hunt, how 
to live in their environment. It would be like taking a bushman from 
West ^Vfrica and raising him in Chicago, then taking him back out 
there and saying, "OK, guy, you are on your own." 

You cannot raise a canid in captivity and expect it to operate in the 
wild. 

Mr. DB LA Garza. It is just like taking a United Auto Worker from 
Detroit and trying to make a sheepherder out of him under a CETA 
program. [Laughter.l 

It will not work. 

I understand that Dr. Kun claims an antidote for 1080. Are yoa 
acquainted with that? 

Ms. Perkins. I am not acquainted with it. I thought I was up to 
date on 1080 research. 

Mr. DE LA Gabza. Maybe you ought to brush up on Dr. Kun. 

I am intr^ed by the combination of majors you had — animal 
behavior and political science. How did you arrive at that? 

Ms. Perkins. I thought they worked rather well. 



D,g,tze:Jb.GOOg[e 



105 

Since I was brought up with animals and travelu^ all over the 
wild ki^dom, I felt that 1 had to formalize that experience that I had 
had so I took as much animal behavior as I could. 

I think that in many many coses, pobtics and animal behavior are 
coincidental. 

Mr. DB LA Garza. Are you saying politicians are like animals? 
[Laughter.I 

Ms. Pebkins. Animal behavior is a very positive thing, but a lot 
of n^atlve connotations have been placed upon it. 

Mr. DE LA Garza. Often you hear that a politician is a political 
animal. 

Are you acquainted with the Gladys Porter Zoo in Brownsville? 

Ms. Perkins. Yes. As a matter of fact, my father helped design it 
and I think he sits on the board of directors. I am not sure. 

Mr. DE LA Garza. That is a masterful design and one of the best 
zoos of that size. I regret to say that Mrs, Porter passed away recently. 

That is part of my philosophy of what we are trying to do, so we 
are not that far apart. 

Ms. Perkins. Do you want to put some coyotes in the zoo? 

Mr. DE LA Garza, They have them. 

Ms. Perkins. That is great. I think it is important to have wolves 
and coyotes next to one another in a display situation, so people can 
see that they are really not the same. 

Mr. DE LA Garza. Find a home for those little pups that the Depart- 
ment of the Interior wants to shoot. 

Ms. Perkins. If you want to push that program, Mr. Chairman, 
I wish you luck. 

Mr. DE LA Garza. Thank you very much. We appreciate your 
beii^ here. 

Ms. Perkins, Thankyou very much. 

Mr. DB LA Garza. The next witness is Ms, Fran Lipscomb of the 
Society for Animal Protective Legislation. 

We welcome you and would be very happy to hear from you at 
this time. 

I have not seen the length of your statement, but if you would care 
to summarize or quote from it, without objection, your full statement 
will appear in the record. 

STATEMENT OP PEAK LIP8C0UB, SOCIETT FOS ANIMAI. 
PROTECTIVE LEGISLATION 



Ms. Lipscomb. Thank you very much. That is fine. 

I do want to thank you for the opportunity to testify on this occasion 
on Secretary Andrus' predator control policy. 

I am, myself, a Texan and having grown up and gone to school in 
Texas, I am familiar with some of the problems that are faced in 
Texas and elsewhere in controlling predators. Some of my family own 
a ranch in south Texas. They are raising cattle there. 

In preparing for this testimony, I called them, never having dis- 
cussed predator control with them before, to find out what their 
attitude was toward the coyote and what problems they had on their 
ranch. I must say, I was a bit surprised but pleased to fmd that th^ 



D,g,tze:Jb.GOOg[e 



190 

did not consider the coyote a pest. In fact, they encouraged the 
coyote to stay on their ranch. 

They have hired a biologist to work on the ranch and one of the 
things that he has encouraged them to do, which has been quite success- 
ful, IS to keep their coyote populations table. I spoke with the biologist. 
He said that one of the big problems with the coyote occurs when you 
have an unstable population, when you have kuled too many of the 
animals, and there is a flux in the population. Then there is a lot of 
competition. You frequently get more animals coming into the area. 
Your problems are greatly mtensified. 

The biologist was from Texas and went to Texas A. & M. The 
experience talking to him and my family was quite a contrast to what 
I heard yesterday, which sounded very much as though all ranchers 
and sheepmen were definitely opposed to the coyote. I think that is 
not exactly the case. 

Mr. Wamplbe. May I interrupt for just a moment? Did you say 
that they were in the cattle business? 

Ms. Lipscomb. They are in the cattle business. 

Mr. Wampleb, Not sheep or goats. 

Ms, Lipscomb. They do not have sheep or goats. 

Mr. Wamplbh. I wanted to be sure I understood. 

Ms. Lipscomb. They did say that they had had some problems with 
the animal damage control department. The problem centered around 
one particular occasion when they were having trouble with a puck of 
dogs that were running loose on the ranch. 

They called the animal damage control program to come in to take 
care of the problem and the animal damage control program told them 
that they could not come in and take care of the dogs because the d<^ 
were not classified as predators. 

However, they could get around that if they could come onto the 
ranch and capture and kill all predators that they might encounter. 
Under that circumstance, if they encountered the dogs, they could 
take care of them. 

Unfortunately, they encountered a bobcat prior to catching the 
pack of dogs. 

In Secretary Andrus' new policy statement, which emphasized 
corrective control utilizing nonlethal noncapture methods and focusing 
on the offending animal to the greatest degree possible — my family 
and the biologist would certainly agree — is taking a step in the right 
direction toward correcting the problem that they had. The deptrt- 
ment did not seem quite up to handling this specific problem. 

You mention frequently your enthusiasm for research. As a society, 
we definitely agree that research is very important in this field because 
there are predator control problems. 

We hope that the emphasis in the research will be directed away 
from 1080 and into the area of birth control methods. We consider 
birth control much more humane than any of the available lethal 
methods and it does not have the effect of stimulating births, which 
the lethal methods often do. 

It is a well-known fact that maximum sustainable yield of an animal 
population is usually higher when killing has brought about a response 
in mcreased birth rates. With coyotes, woolgrowers do not wont more 
coyotes. They want fewer coyotes. By killing them, they are actually 



D,g,tze:Jb.GOOg[e 



197 

stimulating the birth rate and getting the opposite of what their 
goal is. 

Further, predation on livestock may be stimulated by large families 
of coyote pups. With research in birth control, you would reduce the 
number of pups and the adults would be more likely to sustain them- 
selves on smaller prey, things that would be easier. They would not 
have to catch quite as many animals. 

With respect to birth control, I have submitted for use by the com- 
mittee a recent paper on the administration of PMHI to male coyotes. 
This is research that is being done by the Department. The author 
indicates that a single oral dose will he evaluated shortly. It is work 



Dprc^ 

The second project, which is still in the grant proposal stage, that 
gives promise for use in female coyotes and feral dogs can he sub- 
mitted. I did not bring that with me since it is a fairly thick document, 
hut if you would like to have more information on it I can certainly 
provide it. 

Substitution of birth control for poisons and steel traps would be a 
tremendous step forward. The new policy would encourage such 
developments if it is well and energetically administered. 

To achieve such ad minis tratiou, the encouragement of this com- 
mittee would be most valuable. It is not easy to create policy change, 
which is what the Secretary is trying to do, no matter how well 
grounded the policv is. It is not easy if the same people who are ad- 
ministering the old policy are now being called upon to administer a 
new policy. I can understand the difficulty that they are probably 
havit^. 

I think it is essential that all the animal damage control personnel 
get behind the Secretary's decision and try to see that it works, 
stimulating the research mto alternative areas to what has been done 
before but has not worked. 

The so-called prophylactic killing of predators has not worked. 
There are some instances of animal damage control programs wherein 
they are making some changes. Kansas is a place where they have 
made changes. Ihey send Government people in rapidly. They look at 
the situation and, I understand, they have been in the past acting 
vfry much in compliance with what the Secretary's decision has oat- 
line 1 for the future for other States, 

The Fish and Wildlife Service should receive formal indoctrination 
and training based on the memorandum. The training should include 
instruction m methods of husbandry that protect livestock. 

You were asking about training of herders. That seems to be some- 
thing that no one is very familiar with. There is a school for herders in 
France. 

In the July 28, 1975, issue of Newsweek there is an article entitled 
"Back to the Fold," which reports that at the shepherds' school in 
Montmorillon, there were 250 applicants this year for SO places. I have 
attached the article to the back of my testimony. It does outline nhat 
herders are paid. 

They are required to spend a year in the Held to make sure that they 
are interested in getting into the work. In other words, they have to 
have some experience before they can even attend the school. 



D,g,tze:Jb.GOOg[e 



There was, at that time, a veiy avid interest. I do not think we have 
examined or offered this kind of training to people. It is very difficult 
to say that it will not work until we attempt it and see if it does. 

I think with respect to herders, there is no reason to insist on the 
importation of foreign hertlers. There is a very considerable move in 
this country toward nontechnological life. I suspect that if an oppor- 
tunity were available, it you did have a training pri^ram, even a 
pilot training program, you would get responses. I certainly think it 
would be worth research money that you have and that is at your 
disposal. 

We hope that the sheep on the western ranges will continue to graze 
for centuries in the future. We do not want to see them confined, as 
are the hogs and veal calves of today. We believe that losses to preda- 
tors can be reduced so greatly by adopting a combination of both the 
modem and the ancient methods. 

The ancient methods would include the use of dogs, which is a 
pr<^am that has not received as much consideration as it needs to. 
There is a program going on in Hampshire College, where they are 
trying to use other dogs besides the Komondor. The Komondor is 
one that the Department of Agriculture has looked at, but there are 
many other herding and guard dogs that could be considered. 

This research is goii^ on in a private way but it certainly could use 
more research funas. 

To sum up, we hope that you will urce the Department to move 
forward with the application of nonleUial, noncapture techniques 
with an emphasis on l^te aversion, as has been mentioned here, and 
birth control; and to devote substantial resources to further research 
and development in these areas ; to substitute the least painful methods 
of killing and capture where these are still being use<l. 

Cable-coated leg snares should be substituted for steel traps and 
sets should be visited, at a minimum, within 24 hours. Cyanide only, 
among the currently known poisons, should be used. No poison which 
does not kill as quickly as cyanide should be used. 

Better care and protection of livestock including more herders and 
sheep dc^s, shed lambing, and provision of adequate food and wa,tet, 



Yesterday, there was some discussion of the support for poison 
in the animal damage control program. The U.S. Fish and Wildlife 
Service commissioned a stu(iy called. Public Attitudes Toward 
Critical Wildlife and Natural Habitat Issues. It was done at Yale 
University. I have a copy of this study for inclusion in the record. 

In the report they found that both informed and uninformed mem- 
bers of the general public overwhelmingly <lisapproved of the use of 
poisons as the least expensive method if animals besides coyotes might 
be killed. Indeed, approximately 90 percent opposed poisons to control 
coyotes, neariy 85 percentrat a mo<!erate to strong level. 

By contrast, sheep producers ami cattlemen strongly approved of 

fioison and, in fact, constituted the only group in the entire study who 
avoretl this contiot strategy. Indeed, difJFerences between the general 
public and livestock producers on poisoning, shooting, and trapping 
as coyote control options were among the greatest of any found in the 
study, with Chi square values at an amazingly high 965 and 778, 
respectively. 



D,g,tze:Jb.GOOg[e 



109 

Even though the cattlemen ami sheep producers were very high in 
their support of the use of poisons, I note that 25 percent of sheep 
pro<lucers did not support tne use of poisons and 30 percent of the 
cattlemen did not support the use of poisons. Even though there are 
high percentages that did, there is still a significant part of the com- 
munity that would look for other alternatives. 

Thank you. 

Mr. DE LA Garza. We appreciate your being here. 

Where is your family, in what county in south Texas? 

Ms. Lipscomb. In Loredo. 

Mr. DE LA Garza. That is Webb County. 

Is what they told youprevalent throughout the area? I think that is 
the general consensus. They want to rid themselves of the offending 
predator, not kill indiscriminately. 

Ms. Lipscomb. That is right. 

I think that your support for that general approach, which the 
Secretary has outlined in his decision, is very helpful. I would hope 
that there would not be need for legislation in this area, that you as the 
committee chairman and as a committee woulii be able to work with 
the Department of the Interior and with those who are interested in 
this issue to develop the most comprehensive and helpful programs to 
the sheepherders. 

Mr, DB la Gahza. Unfortunately, we have not been heard. That is 
the reason for having to introduce legislation. 

The polarization was at such an extreme. Hopefully, we are trying 
to dissipate heat and shed some light by having these hearings. 

Ms. Lipscomb. I think the heanngs are very very useful. 

Mr. DE la Garza. Maybe the Secretary might be more willing to 
accept scientific data whicn, we feel, he did not do. The testimony here 
is that he did not. 

I think, even in contradiction to the Executive order, his decisions 
must be prudent. Someone earUer used the words "arbitrary and 
capricious." We certainly feel that his decision was arbitraiy and 
capricious, but we are not going to take him to court on that. We are 
hopefully goii^ to pass some legislation which is acceptable, at least 
in part, to all of us who agree that there is a problem and who are 
trymg"io arrive at a solution to it. 

One of the ways to arrive at a solution is to have adequate research 
and testing and to arrive at what would be the best combination, 
because no one item is going to do it, not the toxic collar, not the 
shepherd, not the dog. We have to arrive at some combination that 
would be the one that would give the most protection with the least 
adverse effects. 

Ms. Lipscomb. I think you are right. I think that priorities def- 
initely have to be set on a research program. I think that it is difficult 
to put 1080 very high on the priority list because so much money and 
time has been spent on 1080 to this point with not enough information 
resulting that indicates that it ileserves that kind of support and time, 

Earticularly in view of the fact that there are so many other areas, 
irth control for one, that could receive more funding and attention. 
There are other methods that would meet many of the items that 
you are talking about. Without the pups there, you would not have 
them to shoot. 



D,g,tze:Jb.GOOg[e 



200 

Mr. DB LA Garza. We are going to look at every avenue. I will tell 
you one personal problem that I would have in my area. If I were to 
advocate birth control for coyotes, they would not let me come home. 
[Laughter.] 

Mr. Wampler? 

Mr. Wampler. I have one brief comment, Mr. Chairman. 

Ms. Lipscomb, I want to thank you for your very fine and com- 
prehensive statement and your presentation. 

I certainly f^ree with you, as I indicated in the colloquy with the 
earlier witness, Miss Perkins, that there is a need for additional re- 
search. On the other hand, if the administrators and the regulatory 
agencies choose to ignore what the scientific body of evidence is, for 
imatever reason — political or otherwise — then it does us little good 
to have research. 

This is a question that I will address at another time in legislation 
that I have introduced. I intend to set up a national science council 
that will make these scientific determinations when they arise. Then, 
whatever the findings of that council are, they will be binding upon 
the regulators or administrators. They will have no discretion. 

I stul have to come to the conclusion and agree with my chairman 
that thus far the evidence before this subcommittee is that Secretary 
Andrus' decision last year was highly politically motivated and is 
against the substantial scientific evidence that is before us. 

I just want to make that point. Just doing research alone is not 
adequate. We have to use it intelligently once the determination is 
made. 

Ms. Lipscomb, I think, too, though that it works in reverse. It 
seems that there was a decision made on 1080 but basically the cattJe 
and sheep industries continue to push the 1080 research and the 1080 
poison, never givii^ up hope that they would get it back. I think that 
naa skewed a lot of the research effort for the past 7 or so years. 

It would have been very helpful if those research funds had been 
spread into other, perhaps more productive, areas. I hope that happens 
in the future. 

Mr. Wamples. Let me just say that I think that there is evidence 
before the committee, and there will be more witnesses before this 
committee this afternoon, that would refute that and would say that 
the research on 1080 offered the greatest single hope of something 
constructive. Of course, reasonable persons can disagree on that, but 
that is the way I understand it, at least up until this point in time in 
the hearings. 

I do not want to belabor the point. I understand what you are 
sayii^. Where you have limited research funds you ought to use them 
in terms of an assessment of priorities and those concepts or methodolo- 
gies which do offer the greatest hope of finding an answer to a problem 
should be on top. At least, that is how I conceive of it. 

I do thank you so much. 

Ms. Lipscomb. Thank you, 

Mr. DB LA Garza. Thank you very much. We f^preciate your 
testimony. 

[The prepared statement of Ms. Lipscomb follows:] 



D,g,tze:Jb.GOOg[e 



SOCIETY roil ANIMAL PMTKTIVl UIQWLATKW A*^^!-—- 

vi t tti n aan. o.cteata 

STATEMENT FOB OVERSIOaT HEARIBGS OH THE POLICY STATEMENT BY THE 

SECRETARY OF THE IHIERIOS ON THE AHIKAL DAMAGE COHTBQL PSOGRAM 

BEFORE THE HOJSE AGRICULTURE SUBCOWdTTEE ON DEPARTMENT INVESTIGATIONS 

OVERSIGlrr AND RESEARCH 

April 17, 1980 

by Fran LipscOHb 



Control program from which Secretary Andrus developed hia new 
policy statement, and the Society for Animal Protective Legislation 
opposes any legislative attempt to drcunvent the process of public 
Involvement and study which led to thia new policy. We urge this 
Coomittee, Instead, to encourage the successful implementation of 
the new policy. 

As a Texan, myself, I am familiar with the predator control 
problems faced by ranchers and molgrowers. Some of my Eaailly 
raise cattle in South Texas today, and in preparing this testimony 
I talked to them and found that rather than seeing the coyote 
as a villain to be eradicated by ^n' means available, they encourage 
coyotes to remain on their land. The coyotes are a barometer of 
the health of the wildlife on the ranch. They feed off prey species 
on the land, keaplng then In check, and a thin coyote la an early 
indicator of problems in that Environment. 

My family's coranltment to the animals at their ranch, both 
the wildlife and the livestock, has been so great that they hav« 
hired a professional biologist to work there full time, and his 
opinions concerning predator control were very interesting. 

He said that returning to the use of 1080 would be a giant 
step backward. It was, he said, too sasy to misuse this deadly 
compound, and because of the secondary poisoning effect of that 
misuse, too many nontarget species would become the victims. He 
favored Instead preventive approaches, such as repellents, and 
where persistent problems occur, the use of the M-44. 

His primary compalnt with the Animal Damage Control program 
centered around an occasion when he had problema with a pack of 
wild dogs on the ranch. ADC said dogs were not classified as 
predators, therefore, they could only help him if they could trap 
for all the predators on the ranch and If they happened to catch 
the dogs in the process, then thsy could gat rid of then. 

Unfortunately they killed a bobcat before removing the marauding 
pack of dogs. Secretary Andrua' new policy statement, which 
emphasizes "corrective control, utilizing non-lethal, non-capture 
methods and focusing on offending animals to the greatest degree 

fosaible," Is a step in the right direction toward correcting ADC's 
ormer inability to go after offending animals only. 

The ranch biologist felt a policy Is clearly needed that 
responds to the livestock producers In reducing leases of sheep 
and lambs by predators, while having a minimal effect on wildlife— 
predator and innocent nontarget victim alike. 



D,g,tze:Jb.GOOg[e 



upon examination of The Secretary*! refonoe. It la evldant 
that they are extremely modeit. Only Cm Imiedlat* actions were 
taken. He stopped all research on Compound lOSO and he stoppad 
the practice o£ denning. 

On the other hand the record is thick with reasons for 
changing the predator control policy. Large stms of noney 
have been spent without achieving the intended results; pro- 
tection of livastoclc. 

The DeparCiaent of the Interior's own internal audit In 
1978 was unable to detemtlne Chat the Animal Damage Control 
program had actually succeeded in protecting any domestic animal, 
though It had certainly succeeded In expending a considerable 
HMunt of money. The audit stated, "Fish and Wildlife Service 
cannot effectively determine whether the estimated expenditures 
of $18 million In fiscal year 197S had a significant impact on 
the prevention of livestock losses by predators in areas where 
ADC methods were utilized." (Review of the Anioial Damage Control 
Program, U.S. Fish and Wildlife Service," November 1978) 

I wish to emphasize that the Society for Animal Frotecttv* 
Legislation is just as interested in domestic animals as it Is 
In wild ones. The first federal law tdtlch this Society took a 
leading role In passing was the Humane Slaughter Act of 1958, 
and we were equally active In obtaining passage of the 1978 
amendments which broadened and strengthened this Important statute. 
These laws protect livestock from cruel slaughter and handling. 
We are not opposed to killing animals when necessary. If it la 
done humanely. Predator control, as It has been carried out by 
the Department of Interior, however, has been extremely painful 
and terrifying to wildlife, and massive numbers of animals hava 
been maimed and killed without achieving the Intended rssulti 
protection of livestock. Their suffering was needless. 

Under the policy outlined In the Secretary's Memorandum 
there will still be more suffering Inflicted on wild creatures 
than we believe Is necessary, but the total amount should ba 
significantly reduced. We applaud the effort to move to control* 
which are as rational and humane as possible. 

We hope the Congress, led by this distinguished Cosadttee, 
will support the non- lethal, non-capture methods encouraged by 
the Hemorandum, In particular, we urge development and use of 
effective birth control methods for coyotes In areas lAare frequant 
predatlon Is reported. Birth control Is clearly more hUEOane than 
any of the available lethal methoda, and It does not have tha 
effect of stimulating births which lethal methods often do, co*- 
poundlng the problem they are Intended to solve. 

As is wall known to wildlife biologists, the bmxIm 
sustainable yield (HSY) of an animal papulation Is usually 
higher wh«n killing has brought about a response In incraased 
birth rates. With coyotes, however, voolarowers are not ■••king 
to Increase tha population so they can kill aa many indlvlduala 
as possible. On tn« contrary, the purpose Is to keap the popu- 
lation low and stable. 

Further, predatlon en livestock may ba ativulatad br larga 
families of coyote pupa. Without pups, adults are mora likaly 
to sustain themselves on rabbits and rodants. 

It has often been obsarved that a resident pair of coyotaa 
keeps out Intruding new coyocaa frt>o might attack livaatack. Tfaua, 
maintaining an old pair nay provide innmrtant protactlon agalnat 
other coyotes. This tendency can now ba heavily reinforcao by 
training a resident pair to stay away from sheep by aoaos 0< 
taste aversion. 



D,g,tze:Jb.GOOg[e 



According to the Saskatchewan Departnant of Agrlcultura: 

"Keep dead she«p or lamb* for coyote bait. By 
Injecting them with lithium chloride, you can keep 
coyotes away from yoursheep all (tjiBiier.> 

"Lithium chloride la a chemical available through 
Saskatchewan Agriculture. You can prepare coyote bait 
yourself using dead animals or remains of a coyote 
kill. But before you do, check with Saskatchewan Agri- 
culture for details... 

"When your baits are ready, spread the bait near 
the sheep pasture. Place baltt near sheep trails or 
just outside the pasture fence. Every three weeks 
replace baits coyotes have eaten, 

"Lithium chloride In the bait makes coyotes 
violently slclt to the stomach. The coyotes associate 
the sickness with eating the sheep, explains Dr. Jim 
Jowsey, Problem Wildlife Specialist with Saskatchewan 
Agriculture. This shifts their food preference back 
to rodents. Also coyotes that have learned to avoid 
sheep discourage other coyotes from entering the 
baited areas. 

"From August to Sovember coyotes roam to new areas. 
If your neighbour is using lithlim chloride baits, watch 
for coyotes moving Into your pastures in the fall 
and bait your own pasture If you have sheep... 

"One flnol word, if you have coyotes In the 
area and have never experienced predation, leave them 
there ! These coyotes may have been averted to sheep 
by use of lithium chloride somewhere else in the 
province, or may never have preyed on sheep and not 
recognize them as a prey species. Such coyotes pro- 
tect a territory and IE allowed to remain there may 
keep other sheep killers out." 

I would submit, with respect to predator birth control, for 
use by the Connlttee a recent paper on administration of IWHI to 
male coyotes. The authors Indicate that a single oral dose will 
be evaluated following the work reported here in which the drug 
was injected. 

A second project, which is still In the grant proposal 
stage, gives great promise for use In female coyotes and feral 
dogs. This Information can be made available to the Committee 
if desired. 

Substitution of birth control drugs for poison and steel 
jaw traps would he a treoendous forward step, and the new pollcv 
would encourage such developments If It is well and energetically 
administered. To achieve such administration, the encouragement 
of this Comilttee would be most valuable. It Is not easy to 
create a policy change, no matter how well grounded, when the 
same bureaucracy, which has been accustomed for decades to pur- 
suing a policy of attempted extermination, remains In charge 
of carrying out the new directives. 

It is essential that all ADC personnel get behind the 
decision rather than attempting to undercut it. Differences 
of opinion aside, the fact remains that what ADC has been 
ddlng has not solved the problem. So-called "prophylactic" 
killing of predators has not worked. Contrast this with the 
killing of individual predators known to have killed lambs 
In Kansas. The system is well established and has proved effec- 
tive even though it uses only a small number of skilled Indivi- 
duals. These state government men move In rapidly when a report 
of predation Is made to them. They bo to the trouble spot, 
show the sheep owner what to do to kill the marauder or marauders 
and achieve a high degree of success. 



D,g,tze:Jb.GOOg[e 



F«S personnel (hould r»celw« formal Indoctrination and 
training Uaed on the Memorandum. This training jhould Include 
ln«tructlon in raethoda of husbandry that protect llvastocK. 
There Is a school for shepherds- -and shepherdeases--in France 
which is so popular that a large proportion of SPPJ*^^""'^" *" 
turned away even though the courses are arduous In the July 
28 1975 Issue of Nevsweek an article, Beck to the FolO, 
tBDort*. "At the ihepherds' school in MontmorlHon. . ■ ther« were 
250 applications this year for 50 places. The world-famous 
Bergerle Hatlonale in Ranboulllet Is booked solid through 1977," 



W« have no such established school In the United States, 

but interest in the field Is demonstrated by such projects 
as one at Hampshire College. Amherst, Massachusetts, where the 
Hew England Farm Center at Hampshire College Is raising, training 
and distributing traditional breeds of livestock guarding dogs: 
the Maremma from Italy, the Shar Tlaninetz from Yugoslavia, and 
ths Karabaah from Turkey, Over the centuries different breeds 
of dogs have been developed to guard the flocks and/or to herd 

A recent arttcis on border colliss tells of a doe naoMd 
Nickey 1^ would entice lambs to play with him. "He'd sta.rt 
running with 25 or 30 lambs chasing after him. Then he'd roll 
over on his back and the lambs would jump over hln and then 
turn, come back and play at butting hira for an hour But when 
Doc gave the working v^istle the frolic stopped. Nlckey -was on 
his tset with the look in his eye that the Iambs knew meant the 
games were over and he meant business, 

"The same Nlckey was featured in 'Arizona Sheep Dog.' A 
mountain lion was used la some of th« £cene£, and when « scene 
was finished several men would maneuver him back Into his caga. 
One evening the lion got out of control and tried to escape 
into the open mountain country Doc was helping the men in 
their attempt to contain him when Mickey caitae up and put his 
' ay*' on the lion. This had more effect on the big cat than 
the men had, so they stood back and left it to Doc end Hickey 
to herd the animal into his cage. And it became their job to 
do Lt from that time on. 

"The point Doc makes with this illustration is that the 
dog with friendly eyes for. the playful lambs could change them 
to highly intensive ones to control the dangerous lion. Physically 
the cat had the power to kill, but it couldn't stand up to the 
strength of the eye' of this courageous little dog. 

"What every shepherd hopes to find In a dog Is a good com- 
bination of 'power' and 'eye A dog that knows no fear, that uses 
Its eyes as enforcers and Is able to coninunlcate Its coucags. to 
the stock it's tending doesn't n*«d to use roughness; it can 
control them In a calm, businesslike manner," 

The great int 
remarkable skills, 
legendary. 

Fewer of us h»ve had the privilege of making the acquaintance 
of a Komondor, a bigt strong dog, fierce as a lion in the protec- 
tion of the flock, but so gentle with lambs that thsv sometimas 
run to the Komondor and disappear under the long curly ropes of 
hair that characterize Che breed Uhen a Komondor runs toward 

a coyote, Its great coat swinging up and down like tha wings of 

a gigantic bird, tha eoyota flees with no ado. 



D,g,tze:Jb.GOOg[e 



The ovnsrs of valuable flocks of fheep have often ore* 
vlded these animals vlth minimal care and protecClon with the 
result that many die of causes other then predatlon. Statistics 
■how, for example, that shed lambing Is moTS profitable than 
range Iwnhlng. According to the "Draft Report on Predator Damage 
Management In the West," Hay 5, 1978, "the higher costs for labor 
are more than offset by the lambs marketed per ewe." 

As an organization Interested in Che welfare of domsstlc 
animals, we respectfully urge this Committee to encourage the 
Departwent to move forward vigorously with the development of 
Improved husbandry and dissemination of Information to sheepmen 
on the benefits of alraady aatablished practice*, such as sned 
lambing. 

With respect to herders, there is no reason to insist upon 
importation of foreign herders. Instead, the very considerable 
movement In this country to get back In touch with non- techno logi- 
cal life should be exploited by woolgrowers and assisted with 
govemnent training programs. Among the hordes of back packers 
who regard it as a privilege to sleep In the open, walk long 
distances, and carry their food with them, future American shep- 
herds could readily be recruited who would be delighted to be 
paid for work in the workplace they are currently paying to 
reach on vacation, With greater care for the sheep by people 
who want to change their life style, much of the predator problem 
could be solved. A man or woman on the spot with a dog and a 
gun has no equal In protection of sheep on the range. Large 
bands of sheep would require ntore herders and more dogs. 

Mr. Chairman, w6 hope that sheep on the western ranges 
will continue to graze for centuries into the future. W* do not 
want to see them shut up In confined quarters as so many hogs 
and veal calves are now. We believe losses to predators can he 
reduced so greatly by adopting a combination of modem and 
ancient methods that predatlon will cease to be 

forward with appllcatlor 

with emphasis on taste aversion and birth control; to devote 
substantial resOii^tflS to further research and development in 
these areas: to substitute the least painful methods of killing 
and capture where these are still being used: cable coated 
leg snares should he substituted for steel traps, and sets ' 
should be visited, at a minimum, within 2'4 hours. Cyanide only, 
among currently known poisons, should be used, and no poison 
which does not kill as quickly as cyanide should be used. 
Better care and protection of livestock including more herders 
and sheepdogs, shed lambing, and provision of adequate food and 
water are essential. 

Consideration of all the animals involved, herbivores and 
carnivores alike, combined with wall directed personal effort 
is basic to the sheep industry's own well-being. 

(AttidmcntB to Che atateunc arc held ia cha (ubemaittce flla.) 



db.Google 



206 

Mr. DE LA Garza. Our next witness is Mr. Charles Howard of 
Meridian, Tex. 

Mr. How£u-d, we welcome you and will be very happy to hear from 
you at this time. I understand you have some slides that you might 
want to present. 

Mr. HowABD. Yes, sir. Can you see them well enough from there? 

Mr. DE LA Oabza. Yes. I think so. 

STATEMENT OF CHASLES L. HOWARD, JB., CATTLE, FECAH, AND 
GOAT FARHEB, MEBIDIAN, TEX. 

Mr. Howard. I probably will not be referring to my slides much. 
I will read my testimony and we will use the pictures to try to impress 
on people's minds the type of terrain, type of operation, the predator 
problem, and the toxic collar. That is how they will be used. 

Dr. Dale Wade will assist me in presenting the slides. 

I am certainly thankful to be here and be able, as a rancher whose 
livelihood depends upon what can be produced from the land, to 
state the problems that we are having in my part of Texas. 

I have Been involved in farming and ranching for 35 years. I spent 
myfirst earned dollar at the age of 7 for my first heifer calf. 

We raise cattle, pecans, and Angora goats in a county in central 
Texas that is well suited for all. We are m a 32-inch average rainfall 
area. 

We have raised Angora goats since 1965, We raised some sheep 
in 1974 but were put out of business by coyotes. We continued to 
raise goats because we had a few small pastures where we had little 
troubre with coyotes. 

We leased and purchased some larger brushy places in 1973 that 
needed goats for brush control badly. We stocked the pastures and 
within a few weeks started losing goats to coyotes. I called in the 
county trapper and he would remove one or more coyotes. Then we 
would have about 6 weeks' relief. 

I also went to a predator control training school and started doing 
some of my own work but this took too much time away from other 
phases of tne livestock-farming operation, so we went together with a 
small group of other ranchers that were having similar problems and 
hired a full-time private trapper. He removed about 80 coyotes per 
year on and around our ranches. 

Therefore, in October of 1978 I thought that we had the coyote 
population down to a point where we could run goats in our lai^e 
brushy pastures. I borrowed money to bring our goat flock up to 
1,100 head. 

By July of 1979 we were losing one or more goats per day to coyotes 
and grey fox. The fox were only killing kids. 'Inis was despite the fact 
that we were penning at night and using all legal means available for 
predator control. 

My wife and I went to San Angelo to a sheep and goat raisers 
convention in that same month. 

There I learned of the toxic collar developed by Roy McBride and 
modified by the U.S. Fish and Wildlife Service. An announcement was 
made at the predator control committee meeting that test sites were 
needed in Texaa. I agreed to cooperate. 



D,g,tze:Jb.GOOg[e 



207 

The test began on July 23, 1979. Ten kills had been documented 
from the work prior to the test by Dr. Dale Wade, a wildlife specialist 
from Texas A, & M. University, 

We had now been forced out of our large pastures into 130 acres 
by day and a 4-acre trap at n^ht. 

We placed 10 collared nannies and 10 kids in this pasture with 600 
lai^e wether goats and allowed them to stay out day and night. We 
penned all other goats at night and grazea them ia fields near the 
bam in the daytime. 

We thought the coyotes would select the smaller nannies and kids. 
They did on the fifth night. Two coUared kids were killed and both 
collars punctured. We then had a brief lull in predation until August 11 
when four collared kids were killed. Ail four collars were broken. Only 
one kid was fed on. 

We have continued to have predation on the ranch at a very 
reduced rate to the point that we do not pen at night, except where 
we have a coyote kimng from the side or rear. Predatory incidents are 
down from one or more per day to about two per month. We have 
found on this ranch that when we find coyote signs in the pastures, 
we will have a kill in 2 days, almost without fail. 

On the second t«st site, 14 miles northwest of site No. 1, we put 
collars out after we had lost four wether goats. In the second week of 
the test we lost one nannie and two kids who had collars punctured. 
Until today we have not lost another goat and we have used no other 
means of control on this site. 

On the third test, which involved 500 wether and billy goats on 
two adjoining 600 acre pastures, we lost 27 imcoUared so&ta and 7 
collared goats to coyotes. We had one or more coyotes filing from 
the rear. 

Since we could not remove these killers with the toxic collars, we 
called in ADC trouble shooters and after seven coyotes were taken 
by traps, M^4, and calling up and shooting, we were left with one 
7- or 8-year-old female who finally killed a nannie by the throat and 

fjunctured the collar. Since that time in September of 1979 we have 
ost only four goats to coyotes in these pastures and we do not pen at 
night. 

At this test site we recovered three dead coyotes Uiat had red dye 
on their teeth and muscle residue of 1080. 

Also on this test site, when we gathered the goats to be sheared on 
April 1, 1980, one rider reported that he saw three red fox. This, I 
think, is further proof that the means we have been using since August 
have been very selective. 

I might mention that these pastures are as much as 14 miles apart 
and those that advocate penmng at night to control predation have 
no conception of the time and fuel that would be needed to do this. 
It would only be putting the killing off until the daytime. 

Anyone who has ever tried to pen 500 goats with mohair six inches 
long in 100° weather from a 600-acre pasture so brushy that you cannot 
ride a horse through some of it knows how futile and ridiculous this 
method is. 



D,g,tze:Jb.GOOg[e 



208 

I would like to mention that during the time we have been conduct- 
ii^ the collar tests we DOticed the white-tailed deer population had 
been greatly reduced on our ranches. Since we prefer to nave a great 
deal of wildlife on our places and spend a great deal of planning and 
managing to obtain this, we were quite concerned with the low deer 
numbers. 

We have quail, deer, wild turkey, squirrel, racoons, ringtail cat, 
red and grey fox, bobcats, and some other small mammals. 

We documented six deer kills on about 460 acres from Ju ly 1979 
until January 27, 1980 — four fawns and two grown does. We ex- 
amined bone marrow and condition of flesh when possible. We could 
find no evidence of malnutrition or disease. 

The coyotes have killed so many deer in the last few years that I 
believe we might have to close our doe season in our county. Deer 
himting brings in about $64,000 in lease money alone to our county, 
not including the money spent on lodging, meals, et cetera, and the 
recreation afforded to the hunters. 

To the right of the picture you will see a dark spot. This is a grown 
white-tailea doe that was kiUed by coyotes. That is the tush mark 
where it went through the upper part of the jaw. 

We have recorded and examined all deaths of deer and goats from 
all causes and found only one case of coyotes feeding on carrion. 

We have not found coyotes killing the weak, sick, crippled. Just 
the opposite, they killed four out of five of my registerea billies and 
many l&Tge wethers, even when there was camon m the pastures. 

Now for the item that most are interested in — 1080 m the toxic 
collar. 

On our ranches we have found no nontai^et primary hazards. We 
have picked up goat carcasses as soon as found and placed them under 
a shed so vultures would not consume them and allowed experimental 
dogs to feed on them each day for up to five days. Dogs showed no ill 
effects. They would just smell about the neck area and move back to 
where the coyotes had opened up the carcass to feed. 

In the field vultures would clean up a goat carcass in one to two 
days, so they would remove the possibility of any hazards from it. 
Since vultures need 30 times more 1080 to kill them than coyotes do, 
there was no problem. 

We also use our stock dogs to gather collared goats, juat like we 
always did. We hunt our bird dogs and hounds the same way as before. 
We have encountered no problems. 

Concerning secondary hazards, we have been unable to find any. 
Coyotes killed on toxic collars have either been lightly fed on by 
vultures or not at all. We found no other animals feeding on poisoned 
coyotes. 

I think that we have shown that 1080 as used in the collar is the 
most selective, effective, humane, and environmentally safe toxicant 
that can be used and this continuous quoting of 1080 hazards is not 
supported by research. Ranchers should not be denied the safe use of it. 

I also believe that according to the Kun report, we should be able 
to use just enough 1080 in a placement bait to kill a 40-pound coyote 
or whatever size we have in a certain area. We would have no secon- 
dary hazards. 



D,g,tze:Jb.GOOg[e 



209 

We operate on all private land and I do not think anyone has a right 
to tell us we must pen, guard, or buUd certain kinds of fences to protect 
our livestock, until they can prove to us that these nonlethal methods 
work, are cost effective, and are practical. Our experience has shown 
that these methods only put off predution until a later time. 

Ranchers in our area do all they can to protect their livestock 
because It is jiart of their livelihood and they do not like to raise 
livestock so it can become part of a coyote's diet so someone in Wash- 
ington or some other metropolitan area can say that there are coyotes 
howling in Texas tonight. 

I thmk it is time the American people wake up and come to grips 
with reality. Four percent of the people in this Nation are feeding the 
rest and are also exporting the surplus. Until we get the impression out 
of our minds of the Walt Disney coyotes chasing a mouse in the snow 
and howling at the moon and come to realize the untold millions of 
dollars of damage they are doing to our food and fiber supply and our 
other wildlife populations, ranchers are going to continue to be forced 
out of business. This will just increase the cost of food and fiber to 
the consumer. 

I would like to attach "Predator Damage in the West" dated 
December 1978. 

We are not asking for extermination of cc^otes but for a realistic 
prt^ram of control that works tmd is economical. 

I urge all of you to put your emotions and myths aside and get down 
to the facts of the damage and costs to consumers that predators are 
causing this great Nation of oura. 

I might add, as just a small item, that coyotes cost my operation 
$41,979 in loss of income in the period from October 1, 1978, until 
September 30, 1979. All this amount was not from actual predation 
loss alone. The indirect losses were worse than the direct losses — 
$27,342 to $14,637. These figures werepublished in Texas Agricultural 
iWress, on page 13, vol. 26, no. 1, liTmter 1980. 

I Know of no other published survey that has included the indirect 
losses or the impact that predation has on the family rancher such as 
myself who is still paying debts for the low cattle prices in 1974 and 
1975 and is putting a daughter through college. 

Because of severe predation in our large brushy pastures we were 
forced into a 130-acre pasture by day and a 4-acre trap by night, 
then finally into 24 acres of sudan prior to the collar test. We en- 
countered a severe parasite problem by doing this due to a wet spring 
and the small area occupied by so many goats. This problem led to 
the deaths of about 90 adult goats and we had to sell 90 head at a 
loss of $40 each. 

We were able to get the herd's health back to normal only by 
repeated drenchii^ and moving them back to our larger pastures 
after we had brought predation down with the toxic collar and other 
methods. 

Also, the goats that were penned at n^ht sheared 0.6 of a pound 
less mohair on a 6-mocth clip at a loss of $2.40 each. The goats were 
compared to two other flocks on a place 2 miles away that did not 
have coyote problems. We lost $1,920 by using the nonlethal method. 



D,g,tze:Jb.GOOg[e 



210 

Another major cost of predatioQ to us and our State is the inability 
to use sheep and goats for weed and brush control for proper range 
management, rather than chemical or mechanical controls which are 
costly, labor consuming, and do not produce a product. 

I would like to attach for the record photographs C, D, E, and F. 

This type of range man^ement is beneficial to deer, quail, wild 
turkey, and other wildlife. 

I would like to submit for the record copies of "Grassland Res- 
toration: The Texas Brush Problem" parts one through five, and 
"Grassland Restoration and Its Effect on Wildlife", as well as "Grass 
for Conservation" (farmers bulletin No. 2093) and "Effects of Predator 
Ckmtrol on Angora Goat Survival in South Texas". 

I firmly believe we need a program that will control predators so 
we can produce from our land. 

In order to do this we must have a program that uses to the fullest 
extent necessary — and I would like to emphasize the word "neces- 
sary" — on our ranches we only use the amount and variety of methods 
that are necessary to bring a predation problem under control. 

I am talking about all lethal and noi^ethal methods that are effec- 
tive, such as traps, M-44's, snares, aerial and ground shooting, place- 
ment baits, and the 1080 toxic collar. We must be able to create buffer 
zones and practice preventive controls. 

The programs must have enough money to get the job done. If they 
are waterc^l down to the point that they are meffective, as the Secre- 
tary of the Interior has proposed, ranchers will pull out of the ADC 
programs and do their own predator control by any means or methods, 
legu or illegal, so that they may survive. 

I beUeve the U.S. Fish and Wildlife Service under the Department of 
the Interior has shown by its actions and policy statements that it 
intends to do very little. 

This being the case for many years, I believe the animal damage 
control program should be transferred to the Department of 
Agriculture. 

Thank you. 

[Photos and attachments submitted are held in the subcommittee 
file.] 

Mr. oB LA Gahza. Thank you very much, Mr. Howard. 

Mr. Wampler? 

Mr. Wamplbr. I have no questions but I do want to thank Mr. 
Howard for his statement and his presentation. I think with the use of 
the slides, it has been possible for us to get a bettor understanding of 
the type of problem he was describing. It seems to be rather common 
in Texas ana other similar areas. 

I certainly want to thank him for his very comprehensive statement 
and his presentation. 

Mr. DE LA Garza. I would also like to thank you, Mr. Howard. 

There has been some testimony that research was done in areas of 
high predation that did not represent the norm. Your documentation 
here of what was done on your land and how it affected you lets us say 
that there is no norm but how it affects you. I think that this will be 
very helpful to what we are trying to do. 



D,g,tze:Jb.GOOg[e 



211 

Also, from the dates which you specified, your problem occurred 
long before this legislation was introduced, so there can can be no, 
even remote, assumption of collusion or prepared testimony for this 
hearing or anything of that sort. 

Mr. HowAHD. That is right. If it had not been for the toxic collar, 
there was only a 2-week lapse of time between my using it and quitting, 
I would not be up here today because we were in the process of sell- 
ii^ out. 

Mr. DE LA Garza. That is what we are trying to prevent. I would 
hope that some of this morning's witnesses would have stayed for 
your presentation, but unfortunately, they missed it. 

We thank you very much. 

We will continue at 2 p.m. 

[Recess taken.] 

APTBBNOON SBBSION 

Mr. DE LA Gabza. The subcommittee will be in order. 

In order to accommodate a gentleman who has a plane to catch 
early this afternoon, with your cooperation, I would ask Mr. John 
Caigile, president of I he Texas and Southwestern Cattle Raisers 
Association to present his statement at this time. We would appreciate 
the indulgence of those ahead of him this afternoon. He must make a 
flight in order to appear at a hearing tomorrow. 

Mr. Cargile, we welcome you and are happy to have you. We would 
appreciate nearing your statement at this time. 

As with the others, without objection, your full statement will 
appear in the record if you see fit to either quote from it or give us a 
summary. 

SIAI£KENT 07 JOHN CABGIIX, FEESIDENT, TEXAS AJTD SOUTH- 
WESTEEN CATTLE RAISEBS ASSOCIATION 

Mr. Cabgile. Thank you, Mr. Chairman. 

I would like to express my appreciation for being allowed to testify 
at this time. I want also to express my appreciation to you and the 
other members of the committee for spending so much time considering 
this problem that is a devastating one to the livestock industry. 

I will not read my statement in the interest of time. I have a few 
comments that I would like to make. 

I am here today as president of the Texas and Southwestern Cattle 
Raisers Association, a 103-year-old livestock producers organization 
representing approximately 14,000 cattlemen in Texas, Oklahoma, and 
surrounding States. 

I am also an individual livestockproducer operating six combined 
cattle and sheeii ranches in the Tom Green area and in Reagan 
County in west Texas. I also operate the livestock market in San 
Ai^elo. We sell about 700,000 sheep and about 300,000 cattle per year. 

Therefore, I believe I understand something about Uie livestock 
industry in the State of Texas. 

I was president of the Texas Sheep and Goat Raisers Association 
when these problems started in the early 1970's. Now, here we are 10 
years later. We still have tlie problem. Nothing seems to have changed. 



D,g,tze:Jb.GOOg[e 



212 

Over the years I have met with Mr. Ruckleshaus, when he was in 
charge of the EPA. I met with Mr, Jellinek. I met with Rogers 
Morton when he was Secretary of the Interior. We have testified at 
hearings. We have done everything we could think of to do and nearly 
everytnii^ that we have been asked to do. However, the situation 
continues to deteriorate. 

Frankly, sir, it is very discouraging. 

The environmental people say, "We know you have a problem. We 
need to find another solution to it. We want more researcn to look for 
better ways to answer your needs." We do the research and then they 
will not accept it. 

They wanted selective control. We developed the toxic collar. Now 
that is not acceptable. 

We have done research on 1080, concerning its continuing to kill 
within the chain. The scientific people say that they do not have all 
that big a problem with it. Now the Secretary of the Interior says that 
he is not going to recognize that research. 

It is very similar to what we have been dealing with on the subject 
of 2,4,5-T. The EPA wants to withdraw the use of 2,4,5-T for brush 
control. They are holding hearings now on that. 

The EPA appointed their own scientific advisory panel. I would 
assume they selected good people to evaluate 2,4,5-T. The panel came 
back and reported to them that they saw no potential for harm to the 
environment or to people from the use of 2,4,5-T. The EPA ignored 
the advice of their panel and have gone right on with their hearings 
to withdraw its use. 

We keep hearing about nonlethal control methods. I do not know 
of any nonlethal control methods that are working today and I do not 
know of any of them that are practical. 

These people come up here and talk. Talk is cheap. Most of them 
can tell you about what they heard or about what somebody told them. 
Very few of them have had any hands-on experience witn managing 
domestic animals. 

Anybody that does not understand that the statement made by the 
Secretary of the Interior, that we need to manage these domestic 
animals so that they do not come in contact or conflict with predators — 
if you do not understand how ludicrous that statement is, you just do 
not understand anything about domestic animals. 

About one-third of the United States is grazing land. The only way 
you can utilize that natural resource is with domestic animals. I 
submit, sir, that this countiy is not wealthy enough for us to simply 
forget about using that much of our national producing ability. 

In response to the Defenders of Wildlife's statement here this 
morning wherein they talked about cattle losses, the gentleman very 
clearly stated that the coyotes were not killing enough cattle to amount 
to anything over 550 pounds in weight. Of course, coyotes cannot kill 
an animal over 550 poimds. 

He did not point out very clearly, however, that according to the 
data collected by the U.S. Fish and Wildlife Service, coyotes are 
killing I.l percent of the calves in the Southwestern part of the United 
States. The value of those calves today is $32 million annually. This 
problem is growing. 



D,g,tze:Jb.GOOg[e 



There has been a lot said here today about the sheep and eoat 
industry, but as the coyote population has exploded due to lack of 
control, in the last few years the problem of coyotes killing calves in 
Texas has increased substantinlly. The cattle industry is becoming 
more and more concerned about it. 

In talking about the loss reports, I would like to point out that they 
failed to talk about the people who have been forced out of business. 
They say: "Well, there are a few people who are having some serious 
losses and some of them are losing 5, 10, or 15 percent of their animals." 
There is another group of people out there miose losses got up to the 
50-percent level and they sold their livestock. They sold their sheep, 
or goats, or whatever it was and went out of business. Those losses are 
not reported anymore because there is no one there to report them. 

There is a big volume of production out there that no longer exists 
because these things have happened. When he says that farm flocks 
do not have problems, he does not know what he is talking about. We 
used to sell hundreds of thousands of aged breedii^ ewes out of west 
Texas to go to the farm flock States. 

When a breeding ewe in west Texas reaches about 6 years of age, 
she can no longer produce successfully out there in that semiarid 
climate. But if you will move her to a better environment where there 
is more feed, she has 2 or 3 more years of productive life left. 

Up until a few years ago, until these predators devastated the 
farm flock States — from Oldahoma up to lowa^ — we sold a lot of the 
old ewes to go up there. That market is gone. The sheep are not there 
any more. They are not producing any more and we are taking a 
smaller price for those old ewes today. 

A lot of them are going to slaughter rather than having another 2 
or 3 years of useful lite. 

Now, the gentleman said that he was not so sure that we needed 
the lamb and wool business, that we could buy from abroad. I submit, 
sir, that we can buy all the lamb meat we need. We can probably buy 
all the wool we need from Australia and Xew Zealand. If we will start 
buying all the beef we need, they will gear up and start selling us all 
the beef we need. The foreigners can sell us all the automobiles we 
need. Up until recently they were sellii^ us all the oil we needed at 
a very reasonable price. 

However, I think there is something to be learned from the oil situ- 
ation about what happens to you when you become dependent on 
foreigners. Second, if we decide we are going to buy everything we 
need somewhere else, I do not know how we are goii^ to pay for it. 

I do not think there is any difference in the operation of this country 
from the operation of your household or mine. We cannot consume 
more than we produce. 

If we do not produce it, we are either going to have to stop con- 
suming it or try to get someone to lend us the money and I do not 
know how long they are going to lend us the money to buy things 
that we are not producing. 

These teatime environmentalists recommend that we get plenty of 
sbeepherders to take care of all these sheep. I do not know what their 
recommendation will be to take care of our cattle because we just do 
not handle cattle with herders. 



D,g,tze:Jb.GOOg[e 



As you well know, Mr. Chairman, cattle run over a big area of 
south Texas and you do not see them very often. When coyotes staxt 
killing those calves <lown there, a herder couhl not do anything about 
it. 

In old days, up until we got into the situation we are in now, 1080 
worked as a coyote population suppressant. It kept cattle losses down 
to the point where they were nonsignificant, but that is changing 
today. They are getting out of hand. 

Concerning this humaneness issue, how ba<l it is to kill a coyote 
because it hurts the coyote, I submit that these domestic ammals 
also have a nervous system. It hurts them when a coyote kills them. 
I do not know of any scene that, I think, is more repelling than a 
heifer that is having calving difficulties that has been attacked by a 
group of coyotes and is just eaten alive is what it amounts to. 

It is a long, slow, laborious process. Coyotes can be rather vicious 
from the standpoint of humane treatment of other aminals. 

One of the prime considerations of the whole countiy today is 
inflation. There is quite a debate on about what causes inflation, but 
I do not think that there is much debate among the economists that 
one of the best answers to inflation is increased productivity. The 
tldngs that are being done to agriculture, especially on this predator 
issue, are decreasing productivity and we cannot afford it. We need 
to use our domestic animals to produce to the height of our ability. 

Some people idealistically would like us to have a pristine environ- 
ment as we had in this country several hundred years ago. That is 
nice. I would like to see it too, but I do not want to live like the 
Indians lived when they had that environment. I think there is a 
tradeoff that has to be made. We have to make compromises. 

I think, from a practical standpoint, you have to give more pro- 
tection to the livestock industry today than we have been receiving 
because we are in a deteriorating situation and we have not been 
helped any. No improvement has been made in the last 10 years. 

With that I will conclude, Mr. Chairman. 

Mr. DE LA Garza. Thank you very much. 

Mr. Wampler? 

Mr, Wampler. Mr, Cargile, I thank you very much for your 
statement. I appreciate it. 

Let me assure you that your sentiments are generally shared by a 
number on this committee, and I trust, in the Congress as a whole, I 
think you have touched on some very fundamental questions. 

The very fact that we enjoy this abundance of food and fiber today 
is no accident. It is the result of a loi^-term conunitment made 
many years ago. 

It has been said many times that the United States can compete, 



agriculturally speaking, with any nation in the world. This is due to a 
number of factors — soil, climi 



loi^-t 

le Uni 
1 in th 
ate, but probably most important is 
productivity. 

It has been pointed out time and time again that fewer and fewer 
farmers and ranchers are producing more and more food and fiber. 

What has been disturbing to me has been the decline In the rate of 
increase of productivity in agriculture sectors, inflation, of course, 
being the pnmary culpnt. However, I think needless r^ulations have 
been a major contributor to this and I tried to indicate this in a 
statement this morning. As we are addressing the root causes of 



D,g,tze:Jb.GOOg[e 



215 

inflation, we are goin^ to have to look at productivity and see why our 
productivity is declining in this country, while in many other industri- 
alized societies it is on the increase. 

We priced ourselves out of competitive world markets in many 
goods and commodities, but we are still competitive in agriculture. 

I recognize and acknowledge that in a society like ours some regula- 
tion is inevitable because not everyone chooses to play by the rules 
of the game to adhere to the spirit of the Golden Rule, but this 
whole realm of needless regulation and overregulation is, I think, what 
the American people are rebelling against. 

If I hear the message in my constituency in southwest Vii^inia 
correctly, it is not very different from what I am hearing from Texas 
and other great States of this Union. It is that people are getting tired 
of it. 

I do not think that there is a person in this room that knowingly 
wants to do anything to harm the environment or anythii^ that is a 
part of that environment, hut somehow we must get a better sense 
of balance and reason into these equations. Otherwise, as you point 
out, we can turn to world markets to insure that we have what we nave 
to have. I just wonder how much longer we can continue to do it 
without seeing a rather serious change in our life style in this country. 

The word "opportunity" might not be as meaningful as it once was 
if that happened. 

I would like to think that you and I are seeing generally eye to eye 
on the philosophical ideas, but I know you dia not come here to 
discuss philosophy but to try to get some meaningful rehef from a real 
problem. I just want to assure you that the chairman and I — and I 
know I speak for every member of this committee — want to do 
something meanii^ul but we want every person of good will to sit 
down and tiy to help us iind the answers. Your testimony will be 
extremely helpful as we strive for those answers. 

I want to thank you so much for you taking your time to come here 
and be with us. 

Mr. Carqilb. Thank you, Coi^ressman, I appreciate those 
remarks. 

Mr, DE LA Gabza. Mr. Cargile, in your prepared statement or the 
statement from your association there is a suggested change to the 
bill which would give a further explanation as to the reason for the 
research. I do not think we will have any problem with that. 

"The Secretaries of Interior and Agriculture will work jointly in the 
program for the protection of livestock and wildlife." That was how 
you worded it. I do not think the committee will have any problem 
with that. 

We thank you very much for your presentation. It will be very 
helpful when we have witnesses or persons that are directly involved 
in the business rather than a professional who speaks for an oi^ani- 
zation. 

In your stituation, we very much appreciate the fact that you speak 
from personal experience in addition to representing the organization. 

We thank you for your contribution. 

Mr. Carqile. Thank you, Mr. Chairman. We certainly appreciate 
your interest. 

[The proposed statement of Mr. Cai^ile follows.] 



D,g,tze:Jb.GOOg[e 



SUTEMBMT OF Jim CARGILE, PRESIDENT, 
TEXAS AND SOUTHWESTERN CATTLE RAISERS ASSOCIATION 

Mr. Cluiiriniiii and membera of tha Subcommittee, my nunc 1* John 
Cargite. lam bere today a> PiBsidenl of the Texaa and SouthweBtern 
Cattle R»iier* AssocUtion, ■ lOS-year-old livestock producers' organiEBtloi 
representiag approximatelr 14. 000 cattlemen in Texas. Oklabonia, and 
surrounding state*. I am also here as an iodivldual livaatock producer 
operating six combined cattle and iheep ranchei In Tom Green, Irion, 
and Reagan counties of West Tens. 

I am pleased to endorse OD bebaU of TSCRA and myself H. R. £725, 
the Animal Damage Control Act of 1980. Existing legislation ii ineftec- 

llvei tack -producing areas of our nation. 

I underline control, not eradication. It wUL offer protection to the live- 
stock industry from increased financial loeaes and does much to preserve 
our predator sensitive wildlife. 

Before addressing the specifics of the proposed legislation, let me 
quickly capsule the economic unpad predators and current predator con- 
trol programs are having on the naembers of my organization. Statistical 
information on losses is hard to come by, but I can refer to the draft 
laport antilLed "Predator Damage Management in the West", released 
May 5, 1978. by the U.S. Fish and Wildlife Service. It calculate* that 
in the Southwest region, where I reside, there are B, 381,000 calve* born 
each year. Using th« ServiEa's minimal pradatloa Ikctor of 1. 1%, w* (lad 
that appnsimataly 92, 197 baby calves ar* lost to pradatsra. Oa today** 
market, these calves have a per head value of about $350. 00. Total loss 
each year by animal predators. ..to cattle producers only. ..than is 
$32,268,000. The predator situation, a* you can ■••, i* very *srloa* 
and, quite frankly, out of hand. 



D,B,i..ab,Google 



The chemical compound lOBO w»* the nuln method oC predator control 
used in our area, for ZO yean, but atCer the celeaie of the Leopold Report 
in 196B. the Department of Interior changed iti approach to animal 
damage control dramatically. Finally in 1972, without any supporting 
evidgoce, an Executive Order was issued that diaarmed ua. . . Cwnpound 
lOSO was banned. 

On November B, 1979, Secretary Andrus dropped the other shoe with 
the issuance of hla policy statement on Animal Damage Control. He asked 
livestock producers to accept loase* of a percentage of their animals 
before any predatory animal control protection would be available and to 
implement impossible roanagsmant practices that would alledgedly keap 

predators. The Secretary's recommendations are totally unacceptable 

to the livestock industry. It is my feeling that these recommendations were 

politically motivated rather than being based on scientific information. 

see this legislation as the way. Specifically, we wholeheartedly endorse 
the concept of accelerated research and the development of new chemicals 
effective In control, but harmless to the environment. In the interim, we 
ask that lOSO be returned to us until a suitable altarnatlv* is developed. 
No predator control program will be effective until it extends to both 

program be conducted on public lands which will offer protection to both 
livCBtock sod wildlife. If this is not done, federal lands will continue to 

Section Z, Paragraph 4 would direct the Secretary of Interior and 
the Secretary of Agriculture to jointly develop and carry out a balanced 
ADC program which effectively otiliies both lethal and non-lethal control 
practices. This paragraph describes what the predator control program 
will encompass and how it will be conducted, but it does not say "why". 
The only reason for a predator control program is for the protection of 
livestock and wildlife. Therefore, we recommend that the words "for 



D,g,tze:Jb.GOOg[e 



tha protection of Uvaitock »nd wUdlife" be iddsd to Une 15. Pkga Z, 
immsdiately following the word "in*>aut«>". 

Even iE this legislation !■ ilgned Into law and the funda made aTailable, 
It would probably take three to live yeare before an effective control program 
could be implemeBted to apolet whare liveatock loaaea would begin to 
decling. By then, an additional $90 million in loiaea would be Incurred 
by livestock producers. Because of this, ve recommend that additional 
funds be made available to implement the new program using eiiating 
control methods. 

Ws strongly endorse the formatim of an ad hoc committee with ptodncar 
representation to coordinate and review any federal afforte in animal 
damage control. This Is provided for by this legislation, and I emphaalee 
that considerable attention should be given to fair and equal representation 
of all Interested parties an that committee, keeping in mind that the 
purpose of predator control U the protection of livestock and wildlife. 

Even though M. R. b7Z5 does not cooslder transfer of the ABC program, 
I would like Co mention that it has been a long-standing policy of our 
Association to return animal damage control to USDA from the Department 
of Interior. This policy haa not changed, and the blatantly biased 
philosophy of the Interior Department against livestock producers onder- 

Because of Interior's negative attitude toward predator control. 
losses to predators are making serious Inroads in the ability of the live- 
stock industry to produce food for our country. Economists agree that 
increased productivity is one of the best tools ve have to combat in- 
flation. It is in the public Interest to control predators effectively so the 

H. R. 6725 provides the direction for an effective ADC program, and we 
urge your support for its passage. 



D,g,tze:Jb.GOOg[e 



219 

Mr. DE LA Garza. I think probably, if it is agreeable to the next 
three gentleman, you m%ht appear together as a panel and we will 
hear from you individually, of coui-se. 

We have Dr. Fred Knowlton, Dr. Dale Wade, and Mr. Guy Con- 
nolly. We would invite all three of you gentlemen to come to the 
witness table. 

We woul<! hear you in the order in which you appear on the list — Dr. 
Knowlton, Dr. Wade, and Mr, Connolly. 

Without objection, your full statements and enclosures will appear 
in the record. You may proceed as you feel is amenable to you con- 
cerning the way you make your presentation. 

Dr. Knowlton? 

STATEMENT OF TREIlEaiCK E. KHOWITOH, DEPARTMElfT OF WILL- 
LIFE SCIEHCE, UTAH STATE UNIVERSITY; LEADEE, PREDATOR 
ECOLOGY AND BEHAVIOR PROJECT, PREDATOR MANAGEMENT 
RESEARCH SECTION, U.S. FISH AND WILDLIFE SERVICE 

Mr. Knowlton. Thank you, Mr. Chairman. 

I am Fred Knowlton and I am appearing essentially as a technical 
witness to assist the committee. You have my full statement. I will 
simply tiy to encapsulate it by trying to establish my credentials which 
include 10 yeaiB of academic training an<l 20 years of research exper- 
ience, specifically on predators and rnimarily on the coyote. 

I was employed by the Fish and Wildlife Service in 1964 to pui-sue 
research and the understanding of coyotes. That included their biology, 
behavior, predator-prey relationships, and management. My profes- 
sional carreer has been intimately tied with this research and 
management, 

I have been most closely associated with studies of coyote abun- 
dance; population processes of reproduction, mortality, and move- 
ment; predator-prey relationships primarily involving white tail deer 
and coyotes in Texas and coyotes and jackrabbits in Utah and Idaho. 

1 have also been closely associated with some of the behavioral 
research dealing with the animals. 

Appended to my statement are a list of my publications that are 
pertinent to these discussions. 

Thank you. 

Mr. DE LA Garza. Thank you, sir. 

Your full statement, without objection, will be included in the 
record at this point. 

We will hear Dale Wade next. 

Prbpabbd Statement of Frederick F. Knowlton 

I Frederick F, Knowlton, am employed by the U.S. Fish and Wildlife Service 
a% Leader of the Predator Ecology and Behavior Project within the Section of 
Predator Management Research. In that capacity I supervise the activities of 
10 to 12 employees at two field stations administered through the Denver Wildlife 
Research Center as well as monitor certain contract research programs. In addi- 
tion, I have an adjunct appointment to the faculty of Utah State University in the 
Department of Wildlife Science. 

My background includes a rural upbringing and ten years of academic training 
in wildlife science and related fields culminating in degrees awarded by Cornell 
University, Montana State College, and Purdue University. I first became in- 
volved with research on coyotes in 1960 during my graduate program and was 



D,g,tze:Jb.GOOg[e 



220 

employed by the U.S. Fish and Wildlife Service in 1964 specifically to pursue 
further research and understanding of coyotes; their biology, behavior, role in the 
environment, and management. 

My professional career has been intimately tied to research and management 
of coyotes. The research with which I have been most closely associated includes 
studies of coyote abundance and population processes (reproduction, mortality, 
and movements), predator-prey interactions with emphasis on coyote-deer rela- 
tionships in Texas and cove te-jaclcrab bit interactions in Utah and Idaho, as well as 
coyote behavior. I have also been involved with the design and execution of studies 
related to assessing the importance of depredations by coyotes and developing 
means of alleviatii^ such losses. This includes exposure and/or experience with 
nearly all of the techniques employed by the operational Animal Damage Control 
ProgrUQ as well as the administration of that program. 

Appended is a list oF pertinent reports and publications authored or coauthored 
by me in this regard. 



D,g,tze:Jb.GOOg[e 



SELECTED FUBLICATTOHE OF FIEDEUCC 1 



pacta of coyotB piedatlon tn Soath Teiaa with ipaclal rafnane* to 
whlte-tallad daei. Ph.D. DlaMttatlon. Purdua nnlvariltT. UtaTBtta, 
Indiana. U9 pp. 

1967 (Kith S. B. LlBhact) Dcternlnlng age of ec^ataa by coatb-c^wotiB 
layara. J. HUdl. H^tt 31(2): 363-365. 

(ultb D. O. Tralnai and L. Kara cad) Oral papllliBatiiala 1b cha Cofota. 
Bull. WtUl. Dlaaaaa Aawx. 4(3) ii-U. 

196S Coyote predatlon 

or for deteimlDlns 

Mth J. W. UtCla, J 



:. Hlldl. 1 
^cty: A challea 



>lth S. B. Unhart 
976 Potantlal influaaca 



Hat. Parfca . 1. M. JAm (Ed.), pjmS^SSlT 

(ulch L. P. Ruftlaro and C. D. Chanar) iBtaraetlns pray cbaractarlatlc 
affacta on kaatral pcadatory bahailoc. Tba tear. HaturalUt 

113(5) 7i9-j59. 

(Hltfa H. Whlta iDd J. G 
daer la aouthan Taxaa. 
L. Drawa (Ed.), Allen T 



. B. Ela and H. Whlta) Effects ot coy 
f vhlta-tallad dear. lo Proc. Fire 



(with E. A. Gluaalni and D. F. Balph) >ah«l«al pattana of doHa 
ahaep and thKlr relationship to coyote predatlon. Applied Aolul 
Ethology. (In prees, ateepted 11/79) 



(with W. H. TillVowaki) Traoda In bobcat vlaltatloaa to MMat-atatlDH 

aorray llaaa In Waatara Dnltad Statea, 1972-1978. In Proc. Bobcat 
Reaaarch Conf. Front Royal, Virginia, (io piaaa) =- 



D,g,tze:Jb.GOOg[e 



STATEHEMT OF D«LE A. HAfE, EXTENSION UILDLIfE SPECIALIST, 

TEXAS AGRICOLTUBAL EXTENSION SERVICE, TEXAS A » H UN1«£«- 

SITlf SYSTEN 

Mr. Chainaan and Mea^ara of the Coooittea, >y naaa ia Dala A. 
Made. I am Extension wildlife Speclallat, Texaa Agricultural Fxt- 
tenaion Service, Texas AtH Univeralty Syatmi, at the Texaa Am Ra- 
aearch and Extension Center, San Angelo, Texas. 

I am the current chairman of the Western seqicnal Coordinating 
COBiittee for Management of Prsdetora in Relation to EKaneatic Aniiuila 
lmiCC-2e) , whose membership represents the majority of soienttata 
involved in predator- related research in the western United Statea. 
HeaiberHhip of this ccRunittee variea slightly from year to yean at 
present there are 2B members. Among their areas of specialization 
are animal science, range science, veterinary science, chemistry, 
biochemistry, econonics, zoology, ecology, and wildlife. Other 
cooperating scientists include additional disciplines. 

Mr. Chairman, it has been requested by WRCC-26 membership that 
I sunmarize for your committee the WBCC-26 findings regarding th« 
U.S. Department of Interior Animal Damage Control policy stat^nent 
of November B, 1979, and the role of Extension in predator damage 
control. These are more fully described in Appendices A, B, C, and 
D. Apendicee B and F provide a suDmary history of predator daavga 
control operations and research programs. 

Hr. Chairman, the MRCC-26 Committee would like to enphaaiie the 
following points from our analysis Of the OSDI-ADC policy. The analy- 
sis was prepared by an ad hoc committee of HRCC-2e and waa reviewed 
by the entire ccmslttee . 

Hl)CC-26 Analysis of the 
OSDI-ADC Policy Btatawent of November 8, 1979 

General Comments 

The public deserves an objective evaluation of the facts sur- ' 
rounding the issue of predator damage control and a sound ADC 
policy must be based on these facts. 



D,g,tze:Jb.GOOg[e 



liveotock in the Heatern United States causes Beriou* econcnic 
lose to many producers and forces abandonment of a substantial 
number of livestock operations. 

These losses reach levels iriiich prevent proper livestock use 
o£ rangelands and other fordge resources. As a consequence, 
there is a eontimiing irteuersible conversion of agricultural 
land to nonagricultural udes 

In addition, depredation problems cause acute but often unre- 
cognized social and cultural impacts on rural families and 
communities and decrease the quality of rural life. 

These factors eraphaaiie the need for a national policy which 
recognizes and clarifies the importance of livestock grazing 
for production of food and fiber If grazing is a desirable 
use of public lands 6,i a part of this national policy it ahould 
be given appropriate priority The HBCC-2 6 Committee supports 
and endorses grazing of public lands as appropriate under the 
multiple use. sustained yield concept. 

The policy statement emphasizes 'the importance of predators 
to natural ecosystems" However with rare exceptions, which 
do not occur where livestock are produced, natural ecosystems 
do not exist in the United States Moreover a majority of 
liveatock and -wildlife are produced on private lands and many 
of the more serious depredation problaia alao occur On private 

He recognize and support the need to preserve wildlife. We also 
recognize the need to protect and preserve all components of the 
Hvestock industry from excesalve losses to predators. The best 
use and preservation of range resources Can only be accomplished 
with a mix of livestock classes. 

He support the need for a professional ADC program as the most 
aelectixre, effective and sound approach. Howovor, implementation 
of the new usdi-adc policy will not provide the same level of 
livestock protection. 

Collectively the *mcC-26 Conmittee is fuiiliar with all lethal 
BTid nonlethal methods of predator damage control He do not 
support the premise that the emphasis on nonlethal methods in 
the new policy will provide adequate protection of livestock. 

He ate concerned that the 
tions of RK research aci 
tions and that it has no 
of predator damage in the 
pact analysis or to esta 

We believe that implementation oE the policy should be contingent 

Upon deraonsttation and evidence that it does prevent predator 
damage at leaat as effectively as the current program. 

He futher believe that to evaluate its effectiveness the OSDI 
should conduct a series of responsible demonstrations prior to 
implementation. If this Is not acceptable, the policy should 
,be abandoned in favor of one based on established fact and com- 
petent profeasional udgement. If neither of these alternatives 
is acceptable, we suggest that the uSdi ia incapable of conduc- 
ting wildlife preservation and animal damage control functions 
with equal concern for each and we recoiraoend that AdC research 
and operations be removed from DSDI to an agency that is ccrape- 
tant to deal with depredation problems. 







ignores 
























tho 1 


rece 




3tudy 
















scieni 


Lit 


ic facts 











The WHCC-3 6 Committee does no 
ventative controls, phasing a 
of buffer zones. 



D,B,i..ab,Google 



We do not accept or support the premise that nonlathal noncaptur* 
nethoda focusing only on offending animals will provide adequate 
livestock protection. 



I locations and 

CowBients on Policy ReatrictJong on Operational Techniques 

Denning is an economically t 

tion Method and is eai - - - ■ ■ 

atriotion of denning. 
Acclal hunting is closely regulated by federal and state laws 
and regulations. It is far more costly and hazardous than 
is the use of chemical toicicante but has become an eBBsntial 
method. Since the ADC program is conducted on only 11 percent 
of the land area in the western United States and aerial hunting 
and denning on only a portion of that 11 percent ve see no legal 
or biological justification for further restriction of these tools. 
We oppose these further restrictions. 

We support continued use of traps as an essential method of damag« 
control and the use of attractants as a means to increase their 
effectlvenosa apd selectivity. 

We strongly oppose restrictionB on further research and develop- 
ment of Compound lOBO for use in damage control. We also question 
the sincerity of the USDI commitment to permit development and 
use of chemical controls since the lOSO toxic collar, a highly 
selective and effective method, has been prohibited for use by 
USDI personnel just as it has reached the stage of practical 
application. 

NA support the need for additional research into the use of 
toxic baits, including the use of lOSO, for use where predation 
is severe due to excessive coyote .populations. 

Coamenta on Program Operations Directives 



We do not support the concept that another Interagency connlttee 
will contribute significantly to resolution of depredation prob- 
IsDB on public lands unless it occurs through prohibition Of 
llvestack use of public lands. 

We question the proposed mambership of th« interagency working 
group; no representation is suggested for state, county or local 
agencies, or for the affected Industry, all of which contributtt 
funds to the program. 

Comments on Research Directives 



We sariously question the premise that a five-year research 
program will result in practical and effective nonlethal aettiods 
of predation control. Research results over the past decade do 

not lend credibility to this assumption. 



a prohibited fay public land pbllelaa and ngnUtlana. 



D,g,tze:Jb.GOOg[e 



He do not agr«e with tha suphorlc aiQipoFt of lithiuB chloride 
to reduce predatlon. The best available information does not 
support the premise that it Is effective. 

The assumption that species specific toxicants ace currently 
known is in error; they have yet to be found and developed. 
At present there ia no known compound which is as safe and 
selective and has such a significant research base as Compound 
1080. Termination of reaearch on development and use of Com- 
pound 1080 as it reaches the operational stage in the toxic 
collar has no basis in biology, econoniicB, or logic and thus 
is discouraging to research and operations, personnel and to 
livestock producers. 

He believe that if a research advisory committee is Conned 
ooa^etence and knowledge in the ADC field should be essential 
to membership. We suggest that competent ADC research and 
operations staff be appointed to the committee. He also 
request that HRCC-26 be authorized to select one of its members 
to serve on the committee if it is formed. 

The HBCC-26 Committee supports the need for continued research 
on documentation of losses, nonlethal methods, and testing under 
a variety of seasonal, geographic and ranching conditions, we 
also strongly support the need for continued research on Ch«iii- 
cal toxicants, including Compound lOBO. 

Comments on Budget 

Application of the policy statement directives to research and 
operations will require additional time, effort and costs and 
will lead to an increase in livestock losses. Thus, the state- 
ment that 'this level of funding . . . will provide at least 
the same level of livestock protection' is naiva and false 
Since the restrictions imposed will be additive to all others 
existing. 

Summary WRCC-26 Connients on Cooperative Extension in Predator 
Damage Control 

The Extension role in predator dasage control is to provide 
information through an educational system; Extension is not a 
control method or program. Extension does not have the man- 
power, capability or funds to replace operational programs or 
to conduct direct control operations. 

Extension can only extend information which is based on sound 
research and demonstrated application to local situation. Ap- 
plication muat also be fsasibla for each fans or ranch on riiieh 
it is proposed. 

Bxtension of infocBatian is effsctiva and uaefal only if prac- 
tical mathoda to solve a problea exist and can be ployed. 

Effective damage control requires the availability of all use- 
ful methods and flexibility in choosing and applying those Dost 
suitable to each case where control is needed. No single aethod 
is consistently useful in solving depredation problms. 

Providing information may not be effective if individuals do 
not have the resources or extensive training required to deal 
with wary, intelligent, or wide-ranging animals. Trap-sfay 
animals, oiountain lions, and bears are exaa^leB. 



D,B,i..ab,Google 



Extension of information may be inaffactive on arid rang«lands 
irtiere extremely large operating units are required due to low 
carrying capacities for livestock. Similar situations nay occur 

on migratory livestocli: operationE and on public lands. 

Therefore, Extension can provide assistance to producers in 
reducing depredation losses but this must be accompanied by 
an effective operational program in many loss situations. 

Mr. Chairman, this concludes my summary cominentB for the 

Western Regional Coordinating Committee. At the request of 

WIlCC-2e membership I submit the following listed documents 

for the record of this hearing: 

A. Western Regional Coordinating Committee, MRCC-Z6. 

*■- " -' ^ry Qf Interior Andrus • Policy Statement 



nent E 
91 F 



Made, □. A., O. t. Sanders, J. E. Killer, G. C. Halaion, 
and K. J. Caroline. 19TT. Vertebrate Animal Damage 
Control, Summary at panel discussion and committee 
review. National Entcnaion Wildlife and Fisheries 
Workshop, April 26-ZB, 1977, San Antonio, Tenas, 
Proceedinqa: Fourth Great Plains Wildlife Damage 
f^pptrol Workshop. Decembpj j-fi. Tfll . Kannas State 
University, Manhattan, Kansas. (in press] . 
Hade,. D. A. Extension Program Planning for Pre- 
dator Damage Control, Proceedings: Fourth Great 
Plains Wildlife Damage Control Workshop . Decem- 

Kansas. Cin press). 

. Responses of Cooperative Extension State Oirectors _ 

DSOA-SEA EiteuloD Natural RcBourcai. April S, 19S0. 

Wade. D. A. and S. L. Beasom. 1979. The Effects 
of Environmental -Political Factors 
Research, Vertebrate Pest Control ^ 
Materials , ASTH STP 630, J. R. Beck 
Society for Testing and Materials, 



Wade, D. A. 1980. Predator Damage 
Recent History and Current Status, Procee 
Minth Vertebrate Pest Conference , March 4 
Fresno, California, (in press) . 



11 the aubcoHlctH fUs.) 



D,g,tze:Jb.GOOg[e 



Mr. DB LA Gabza. Tbank you, Dr. Wade. 
Mr. Connolly? 

STATEMEMT OP GTTY E. COHHOLLT, WUDLTFE BIOLOGIST, TWIN 
FALLS, IDAHO, RESEARCH STATION, DENVER WILDLIFE EE- 
SEARCH CENTER, U.S. FISH AND WILDLIFE SERVICE 

Mr. Connolly. My name is Guy Connolly. I am a certified wildlife 
biologist with a bachelor's degree in wildlife and range conservation 
from the University of Montana and a master's degree in biology from 
California State University, Sonoma. 

Since April 1975 I have been engaged in research on coyote preda- 
tion control at the Twin Falls, Idaho, field station of the section on 
Predator Management Research, Denver Wildlife Research Center, 
U.S. Fish and Wildlife Service. 

In this capacity, I am the principal investigator for research and 
development of the toxic collar which is a new technique for usin^ 
toxicants selectively to kill only coyotes that attack livestock. This 
ass^nment involves the planning and direction of field tests, as well 
as supervision of pen trials of improved collars, new toxicant formula- 
tions, and nontarget poisoning hazards using captive animals. 

I prepared the application for the EPA experimental use permit 
under which the Fish and Wildlife Service has been using Compound 
1080 in the toxic collar since 1977. To the best of my knowledge, I am 
the only U.S. Fish and Wildlife Service biologist in many years to 
carry out field studies on the efficacy or environmental hazards of 
Compound 1080 as a predacide. All of my work on 1080 has been 
related to its use in the toxic collar. 

In my current position, 1 also supervise research on aversive agents 
such as lithium cnloride, I participated in drafting the U.S. Depart- 
ment of the Interior study on Predator Damage in the West, released 
in December 1978, and in preparation of USDa's Final Environmental 
Impact Statement on Mammalian Predator Damage Management for 
Livestock Protection in the Western United States, released in 
June 1979. 

1 have written comprehensive reviews of predation and predator 
control in the management of big game in North America and on 
coyote population dynamics as influenced by predator control. 

Before taking my present post with the Denver Wildlife Research 
Center in 1975, I worked 12 and one-half years for the University of 
California, Davis, as a staff research associate in studies related to the 
ecology and management of big game — that was from 1962 to 
1975 — and predators — from 1972 to 1975, My research experience 
there included studies of sheep killing behavior of coyotes and simular 
tion modeling of coyote population dynamics. 

My research experience in the area of predator management is 
further described in the attached bibliography. 

Gentlemen, 1 wish you to understand that you are looking at a 
very rare species of individual. You have heard a lot of talk about 
research and the need for research on predators and predator damage 
and predator damage management. 



D,g,tze:Jb.GOOg[e 



2S8 

There are extremely few people iB the United States who are actually 
engaged in such research. You are looking at two of them in the forms 
of Dr. Wade and myself. I think if you were to count all of the people 
engaged in such work in the United States, you could use the fingers 
of Doth your hands — if you have 10 fingers. 

At the request of this subcommittee, I am pleased to appear at 
this hearing to answer any questions you may nave on biolt^cal or 
technical aspects of predator man^ement. 

Thank you. 

Mr. DE LA Garza. Without objection, the material you have sub- 
mitted will be included in the record at this point. 

[The article "Coyote Predation on a Texas Goat Ranch" is held 
in the subcommittee file. The second attachment follows:] 



D,g,tze:Jb.GOOg[e 



Guy £. Connolly—URITINGS PERTINENT TO PREDATOR HANAGEMEHT A 



THE EFFECTS OF CONTROL OH COYOTE POPULATION DYNAHICS, by G. E. Cannally anii 
U. H. Longhurst. University of California, Division of Agricultural 
Sciences, Bulletin 1S7Z. 37p. 1975. 



HOW COYOTES KILL SHEEP, by R. H. Tim and G. E. Connolly. RangcMn's 
Journal 4:105-107. 1977. (REPUBLISHED by the Natitmal Uoolgrower 
70(1):14-15, 1980, and elsewhere.) 



PREDATOR CONTROt AND COYOTE POPULATIONS: A REViW OF SIMirLATIOH HODELS. by 
G. E. Connolly. Chapter M ^n: Bekoff, H. [Ed.). Coyotes: Biology, 
Behavior, and Hanagement. Academic Press, Hex York. 364p. 1978. 

COYOTES, SHEEP AND LITHIUH CHLORIDE, by R. E. Griffiths, Jr., G. £. Connolly, 
R. J. Burns, and R. T. Sterner. Proc. Vertebrate Pest Conference 

8:190-196. 1978. 

TOXIC COLLAR FOR CONTROL OF SHEEP-KILLING COYOTES: A PROGRESS REPORT, by 

G. E. Connolly, H. E. Griffiths, Jr., and P. J. Savarle. Proc. Vertebrate 
Pest Conference 8:197-205. 1978. 

PREDATORS AND PREDATOR CONTROL IN BIG GAME HANAGEHENT, by G. E. Connolly. 

Chapter 2i In: Schmidt J. L. and D. L. Gilbert. (Eds.) Big Game Of North 
America: EcoTagy and HanagMent. The Wildlife Management Institute, 
Washington, D. C. 512p. 1978. 



LITHIW CHLORIDE BAIT AVERSION DID NOT INRUENCE PREY KILLIHG BY COYOTES, by 
R. J. Bums and G. E. Connolly. Proc. Vertebrate Pest Conference 9 
(In press] 1960. 



D,g,tze:Jb.GOOg[e 



2S0 

Mr. DB LA Gabza. Mr. Wampler? 

Mr. Wampler. Thank you, Mr. Chairman, 

I want to express my appreciation to each of you gentlemen for 
your appearance here and for your statements and submissions for 
the record of the documents you brought with you. I thank the gentle- 
man from Texas and I would take judicial notice of your credentials. 

I think it is unique when we have at least two individuals here who 
are generally regarded as experts in this field, a field in which ap- 
parently there is a good deal of confusion and conflicting data and 
honest differences of opinion. 

This morning Commissioner Douglass from West Viiginia, in stating 
the position of the National Association of State Departments of 
Agriculture, commented on the response to Secretary or the Interior 
Andrus' policy statement. In doing so he said that the Western 
Regional Coordinating Committee "is a committee composed of 26 
of the leading predator control and research scientists in the United 
States." That would be a fair description of the committee, would it 
not be? 

Mr. Wadb. Yes, Congressman Wampler, it would be, 

Mr. Wampler. In this regard, Dr. Wade, I wanted to ask you this. 
Prior to the cancellation of the compound 108O as the result of the 
Executive order in 1972, about how much of this toxicant was being 
used in the United States? Do you have some idea how much of it 
was being used in the various States? 

Mr. Wade. I think as an approximation of use in the Western 
United States, west of the one-hundredth meridian, it would be of 
the order of 23 to 24 pounds annually. I do not know how it could be 
divided by State. 

I believe that Wyoming used of the order of a pound annually; the 
State of Texas, I think, of the order of a pound and oue-hali to a 
pound and three-quarteiB per year. 

Mr. Wampler, In other words, it would be fair to say that it was 
used rather sparingly, would it not be? 

Mr. Wade. Yes, 1 would certainly say that. 

Mr. W.\Mi>LER. Let me ask you this. Recommendations have been 
made that we continue to use the facilities of the extension service for 
ranchers who might find improved husbandry practices or other 
methods of controUmg practices. Do you feel this would be an eflfective 
way of doing it, or is this the function of extension? 

Mr. Wadb. Yes, Mr. Wampler, it is a function of extension to a 
degree. I would perhaps recall to vour memory the comments made by 
Di'. Bouns yesterday. That is, there is a need, without question, for 
an integrated approach using the nonlethal methods including animal 
husbandry, fencinir where possible, and others — whatever is appro- 
priate to the terram, vegetation, and geogi'aphy — and lethal methods 
to remove those animals which aie causing serious economic problems. 

As I pointed out in the summary comments, extension is an educa- 
tional method and we can only extend iofonnation which is useful and 
effective in terras of service to the constituents to which we are respon- 
sible. For that approach to be effective we have to have practically 
applicable methods. 



D,g,tze:Jb.GOOg[e 



Many of the people with whom I have contact in the livestock indus- 
try are applying those to the limits of their ability in terms of economic 
and biological possibilities. It is (juestionable in many cases whether 
a<]ditional information extended to them will be particularly useful. 

Mr, Howard, for example, pointed out this morning the difficulty 
of penning goats at night in hot weather from extremely heavy brushy 
pastures. TVe have had direct pei-sonal expeiience with that. I gained 
iivy first education of any sort with goats during the past year on 
Xfr. Howard's ranch and I can attest to the difficulty of carryii^ out 
that kind of an o]>eration. 

It is simply, completely impractical, as Mr. Howard pointed out. 

There are many circumstances which limit the application of 
husbantlry methods. Mr. Howard is one who is applying everything 
within his power in the nonlethal methods of control, without a great 
deal of success at the time we began the toxic collar t«sts. 

Mr. Wami'ler. Dr. Wade, has Texas A. & M. University made 
application for research funds to work on compound 1080 to any 
Federal aj^ency, that is to say, EPA, or USDA, or USDI? 

Mr. Wade. There has been application in the past. Dr. Samuel 
Beasson submitted a request for experimental use of 1080 in small 
placed baits. I believe at that time ne submitted a budget but I do 
not recall the amount to EPA in the hope of having it fQnded. Both 
the request for experimental use and the budget were denied. 

Mr. Wami'LEr. Mr. Chaimian, 1 believe that is all I have for now. 

Mr. DE LA Garza. Mr. Connolly, since you and Dr. Wade have 
done a tremendous amount of work on the toxic collar, it just dawned 
on me that we have been mentioning the collar throughout the hear- 
ings and no one has described it verbally for the record. Could you do 
that foi' us? Could you give us a description of the collar, how it is 
applied on the animal, and the reasoning behind where it is applied — 
a verbal description if you can, sir? 

Mr. Connolly. I would be pleased to do so, Mr. Chairman. The 
toxic collar is the most effective practical method known to selectively 
kill coyotes that attack sheep or goats. I happen to have a collar with 
me which I ivill pass up for your inspection. 

[Toxic collar is shou'n to the subcommittee.] 

Mr. Connolly, The toxic collar exploits the coyotes normal habit 
of killing with bites to the neck or throat of a sheep or goat. 

I will also submit to you a photograph of a coyote Killing a collared 
lamb. 

Coyotes that attack collared sheep or goats usually puncture the 
collar with their teeth, and in so doing receive a lethal oral dose of the 
toxicant. Since poison is released only when the collar is punctured, 
the toxic collar affects only those coyotes that prey on livestock and 
toxicant is exposed only when predation occurs or on those infrequent 
occasions when a puncture is accidentally torn on barbed wire, let us 
say, or prickly pear. 

For these reasons, the method offers a significant technical advance 
that permits ranchers and predator control workers to deal specifically 
and selectively with the individual coyotes that are responsible for 
damage. 



D,g,tze:Jb.GOOg[e 



In arldition, the collar appears to take some problem individuals 
that have escapetl capture by other methods. 

I must, in all fairness, point out that the kno\vn disadvantages of 
the collar include the need for sacrificial lambs or kids; any potential 
safety or environmental hazards posed by the use and occasional 
loss of collars; and the labor and expense involved in collaring livestock, 
monitoring collars, and managing livestock so as to direct preilation 
to the collared animals while at the same time protecting the iincollared 
animals on the farm. 

In addition, the collar is ineffective against coyotes that attack 
livestock at any body site other than the neck. At Mr. Howard's ranch 
we have had approximately 10 goats killed in some manner other than 
by biting the neck. Of ourse, the collar was ineffective against those. 

Like all techniques for reducing coyote predation, the toxic collar 
is more s\iited for application in some situations than others. Vi,'e have 
not yet done sufBcient research to establish the limits of its practical 
application. 

Is that sufficient? 

Mr. DE LA Garza. I guess I could probably add that it is attached 
on the collar of the animal — — 

Mr. Connolly. It is attached around the neck of the sheep or goat 
by means of Velcro neck straps. The model of collar that we have used 
most contains 30 cubic centimeters or 30 milliliters of toxicant. I 
might add that in all of our field research mth the toxic collar from 
the beginning in 1978, we have used approximately 1 ounce of 1080. 

Mr. DE LA Garza, Mr, Connolly, did you say 30 cubic centimeters 
of 1080? If that amount were ingested by a human, what would be 
the effect if the person were of normal size? 

Mr. Connolly. It would contain on the order of between two and 
seven human lethal doses. There would be no effects for a short time 
during n-hich administration of an emetic would save the person's life. 

We do not know how long this time period is. Should a person it^st 
the entire or even half the contents of the collar, it woald undoubtedly 
kill him or her. 

The likelihood of that occurring under conditions of operational iise 
is extremely remote as these collars become rather unattractive after 
they have been on a sheep or goat awhile. You would not pick one up 
off the ground and put it in your mouth I do not think. 

Mr. DB LA Garza. That was my second question. We have on the 
record what that amount of 1080 that is in the collar would to ^"ith 
respect to a human and what the possibility «'ould be of a human 
getting a collar and taking all 30 cubic centimeters out of the collar 
as it appears. You already testified that it would be a very remote 
possibility. 

Mr. Connolly. I think that the prospect of that occurring is so 
remote that it need not even be considered, 

I might point out that in 25 years or more of widespread use in the 
West of compound 1080 as a predacide, by the Fish and Wildlife 
Service, there was nevei' a human fatality in connection with that use. 

Mr, nE LA Garza. Does the 1080 compound, orwhat would be used 
in a collar, have injurious properties to a human if it is not ingested, 
for instance, if one touched it or if a little drop got onto your hand? 
Would it have any effect that way? 



D,g,tze:Jb.GOOg[e 



Mr. Connolly. It would have no detectable effect, sir. You would, 
of course, wash the material off your hands probably without undue 
delay. I have, myself, been accidentally exposed to the liquid, just in 
the course of loading the collars, without ill effects. 

Mr. DB LA Garza. So, your expert testimony is that the possibility 
is so remote that it does not even deserve mention here that any 
human could ingest the whole contents of a collar or become somehow 
injured by superficial contact with the contents. 

Mr, Connolly. I do not think that that is a substantial risk, sir. 

A person could deliberately commit suicide with it, of course. 

Mr. DG la Garza. I do not think they would walk out into a range 
and go looking for a toxic collar to do that. [Laughter.] 

Even that would be a remote possibihty. 

Can you give us a little background or the scientific breakdown on 
10807 What is it? What does it do? How long does it stay if it spills 
on the ground? Could you get into that a little bit? 

Mr. Connolly. Yes, sir. I would be happy to do so. 

Compound 1080, by the way, is the registered trade name of Tull 
Chemical Co., one of the U.S. manufacturers of it. It is also known as 
sodium flouroacetate and DRC 4008. 

Compound 1080, or sodium monofluoroacetate, is a synthetically 
made sodium salt of monofluoroacetic acid, which occurs m nature as 
the toxic principle in many poisonous plants. Most of the plants occur 
in Africa or Australia. None have been found in North America. 

The use of 1080 against vertebrate pests began durii^ World 
War II. Most of the research on compound 1080 as a predacide in the 
United States was carried out by the Denver Wildlife Research Center 
in the late 1940's and early 1950's. 

There are several publications of record on the research by Weldon 
Robinson from 1948 through 1953. 

Even though the toxicant was used by the Fish and Wildlife Service 
to control predators for about 25 years, virtually no research on the 
effects of such use, either on the target or nontarget species, was 
carried out during most of this period. 

Since February 1962, when President Nixon issued the Executive 
orderprohibiting the use of predacides by Federal agencies, the Fish 
and Wildlife Service has not used compound 1080 either in control 
operations or research other than in the toxic collar. 

I might mention that in the years immediately preceding the 
Presidential ban there were some 2,100 to 2,200 pounds of compound 
1080 bein^ sold by the two U.S. manufacturers. About 1 percent of 
this material was used in predator control. The other 99 percent was 
used in rodent control, both for urban and commensal rodents and 
field rodents. 

It is a matter of some interest, I suppose, that the 1 percent used 
on predators seems to generate more controversy than the 99 percent 
that was used on rodents. 

I might point out that even though compound 1080 as used as an 
economic poison in the United States has declined over the past 20 
years or more, the toxicant is widely used elsewhere in the world and 
IS the subject of substantial research elsewhere in the world. 

For example, in New Zealand, a country about two-thirds the size 
of California, some 4,400 pounds of compound 1080 are used annually 
against rabbits and brush tailed opossums. This compare with some 



D,g,tze:Jb.GOOg[e 



22 to 25 pounds beii^ used in predator control in the United States 
immediately prior to the Executive onler, as Dr. Wade testified 
earlier. 

The toxicant is also of major importance in western Australia, 
where some 5 million drop baits are used each year a{?ainst the dingo, 
a wild <io{; that preys on sheep over there. 

Of especial interest in western Australia is the fact that mono- 
fluoroacetic acid, the naturally occurrinf; form of 1080, is a poisonous 

f)rinciple in over 30 species of native lefjumes which are palatable to 
ivestock and cause substantial livestock losses through poisoning in 
western Australia. 

Consequently, that asjiect of 1080 poisoning is a subject of con- 
siderable research there and the ability of animals to consume and 
detoxify Uuoroacetate is under investigation there. 

Native animals that have a high exposure to these toxic plants 
have been found to exhibit an unusually high tolerance to 1080 com- 
pared ^vith the same species resi<ling in other regions of Australia 
where these toxic plants are absent or rare. The resistant animals 
have been shoiivn to be capable, just within the last couple of years, 
of detoxifying fluoroacetat« by defluorination. 

If this seems unduly technical, let me assure you that this phe- 
nomenon is most significant in relation to the possible development 
of an antidote or treatment for fluoroacetate poisoning, which is a 
subject under intensive investigation right now in western Australia. 

In these hearings we have heard from time to time of Dr. Kun. I 
must mention here that Dr. Kun is responsible for a very significant 
basic research fintling on the mode of action of fluoroacetate poisoning. 
It is well known that fluoroacetate itself is not toxic but it is metabo- 
lized in animal tissues to fiuorocitrate which is toxic. 

Traditionally, everyone believed that fiuorocitrate received its 
toxic action by inhibiting a certain enzyme within the cellular mito- 
chondria and that the inhibition was irreversible. With this review, 
no biochemical basis for antidotal treatment could be seen. 

However, Kun has pointe<l out that most of the early information 
in this area is in serious doubt and that any formal view based on the 
textbooks runs the risk of being faulty. Kun and his coworkers have 
su^ested that the toxic action of fiuorocitrate results not through this 
enzyme inhibition, w lich ;vas previously theorized, but rather it 
results from its inhibition of citrate transport through the mitochon- 
drial membrane. 

Again, I apologize if this seems excessively technical. This has 
immediate practical implications, in that it opens some possibilities 
for development of an antidote to 1080 poisoning. 

Mr. DE LA Garza. That is very good, sir. 

Let me ask you this. From your research, what can you tell us of the 
secondary effects in relation to other predators or other wildlife or the 
environment? 

Mr, Connolly. We have heard much of that also today, sir. I would 
be pleased to summarize the state of knowleiige on that. 

I just mentioned a while ago that the Denver Wilillife Research Cen- 
ter has not actively researched secondary or nontarget hazirds of this 
material for many years. As a matter of fact, their research was pretty 
well summarized back in 1948 by Weldon Robinson and I shoufd just 
like to read a paragraph in which he summed up his studies. 



D,g,tze:Jb.GOOg[e 



235 

The employment of 1080 stations and the extent of such use is a matter tor 
serious conKiderBtiun. On the one :<ide, thM method has remarkable ability to 
reduce the most trculJesome coyote populations. This can be accomplished at a 
fraction of the cost of any effectively operating other methods. 

From an economic standpoint the resultant savings of livestock, which other- 
wise would fall prey to the coyote, weigh heavily in favor of the employment of 
this method. On the other hand, these poisons are severe in their killing action. 
TTiey may be dangerou,-; in tte hands of inexperienced crop raisers. There is a loss 
of pelts that cannot be recovered and desirable or neutral creatures inevitably will 
poisoned. 

With careful handling of stations, however, these losses may be kept at a low 

In discussing secondary poisoning, sir, I would point out that there 
lire two kinds of possible unintentional poisoning that must be con- 
sidered in evaluating the use of 1080 or any other toxicant in nature. 
Secondary poisoning in reference to 1080 used against predators would 
occur when a coyote ingests 1080 — let us say the coyote bites the 
toxic collar. He <lies. Any scavenger that feeds on the carcass of the 
dead coyote would be a potential victim of secondary poisoning. 

Let me say here that we have tried to get at this systematically 
by forcing ma^ies, which are a common scavengii^ bird in the West 
and is the species that would be most susceptible to this kind of poison- 
ii^ were it to occur — we have caged magpies after capture, put them 
in a cage with the carcass of a coyote that bit a 1080 collar and died. 
We have kept the magpies in there for a week and given them nothing 
else to eat and we have not poisoned any. 

We had four starve to death. 

We have <lone that with two coyotes poisoned with 1080 collars 
and also with one coyote that we fed the entire contents of a toxic 
collar. This is on the order of a 200-fol(l overdose. Those magpies 
survived as well, even though the entire muscles were fed to a group of 
five mac;pies and their entire intestines, stomach, and other viscera 
were feu to another group of magpies. 

The other type of poisoning that can occur would be called primary 
nontarget hazard. In relation to the toxic collar the main risk of this 
type is presented by the collared livestock itself, fitter a sheep or goat 
is killeu by a coyote who bites the collar, then the coyote will feed on 
the lamb. That is its normal manner. 

The coyote will go its way and die, but then the dead collared 
lamb or goat remains there with the broken collar around its neck 
and any other species of midlife that comes to scavenge on that 
carcass is at risk. 

Here again we have taken a direct approach to the estimation of 
this type of hazariL This morning Mr. Howard showed you a slide 
of a clog feeding upon one of the dead collared goats. We nave made 
three trials of this type with three different collared goats and three 
different ilogs and we have not produced any lethal symptoms or sub- 
lethal symptoms, nor any evidence whatever of intoxication. 

We have also exposed a group of magpies to one of the dead collared 
laml» for a week followed by a second week of panning the magpies 
on another diet, just for observation, with no observed effects on the 
birds, 

Mr. DB LA Garza. Thank you very much. I wish we had more time 
to use the expertise that you gentlemen have. However, from your 
prepared statements and your enclosures, I think you have been 



D,g,tze:Jb.GOOg[e 



most helpful to the committee. No one can say that it has not been a 
fair and impartial presentation showiru; the scientific data on both 
sides, which I think is very commendable of you as scientists. 

We certainly respect and admire your scienti^c work. 

On behalf of the committee and, I am sure, Mr. Wampler, I want 
to thank you for your cooperation and hopefully it will be continuous 
cooperation. We might come to you with questions periodically as 
we work on this legislation. 

Mr. CoKNOLLY. We will be available at any time, sir. Thank you. 

Mr. DB LA Gahza. Mr. Wampler? 

Mr. Wampler. Thank you, Mr. Chairman. It seems to me that 
either this morning or yesterday one or more of the witnesses testified 
that there was no antidote for compound 1080, I gathered from what 
you said, Mr. Connolly, that there is for human beings. I do not know 
whether they were referrii^ to humans or animals. You indicated that 
there is an antidote for humans 

Mr. CoNNOLLT. No; I did not, but there is a form of treatment. If 
you were to accidentally hit one of these collars with your mouth and 
get a mouthful of the toxicant and swallow it, we would have our 
syrup of ipecac handy, as I do today in fact, and we would immediately 
adnunister it to you. You would vomit up eveiything in your stomach 
including the poison. You would then be indebted to me for the rest 
of your life for savii^ you. [Laughter.) 

However, if this first aid treatment is not done — and again, we do 
not know how promptly it must be done to be effective. This is a 
subject that could be researched. You would certainly die from it and 
there is no antidote at this time. 

The research workers. Dr. Kun and the Australian people are 
holding out the hope to us that they may be able to develop an anti- 
dote. As a matter of fact, they have an antidotal procedure that is 
effective in tissue cultures. It is not yet ready for tests on the whole 
animal. 

Mr. Wampler. In view of the results of research on compound 1080 
that have been conducted since 1972, do you feel that the 1972 
decision to cancel 1080 was based on adequate data and documenta- 
tion? I guess I should say, the 1979 memorandum of Secretary 
Andrus. 

It is my understandii^ that since the cancellation order of 1072 
there has been extended and extensive research on 1080. As I under- 
stand the Secretary's memorandum of 1979, it would preclude or 
cancel any future research. Is this decision predicated on adequate 
data and documentation? 

Mr. CoNNOLLT. Well, sir, I do not wish to be in a position of second 
guessing the Secretary of the Interior. I would point out that there 
has been no research done by the Fish and Wildlife Service on 1080 
as a predacide, except in connection with the toxic collar and only 
since 1977. 

I have earlier today reviewed the other kinds of data that were 
available on the use of 1080 in toxic baits. Those data indicate Uiat 
there is virtually no risk of secondary poisoning due to the use of 1080 
in toxic baits for predator control. The data indicate that there is sub- 
stantial risk of nontarget primary poisoning of nontai^t species that 
might ingest the bait material if it is improperly exposed. 



D,g,tze:Jb.GOOg[e 



237 

The placements of these baits then becomes critical in the proper 
use of uie substance and was the subject of very extensive guidelines 
and directions back at the time that it was used. 

Those are substantially the data that are available. 

Mr. Wampleb. Dr. Wade, would you care to comment on that? 

Mr. Wadb. I would like to elaborate very briefly, Congressman 
Wampler, on Mr. Connolly's statement with respect to antidotes. He 
was correct. However, there may be and frequently is a misconception 
of what constitutes an antidote. There are really very few true 
antidotes. 

One of them is "2-PAM," a compound used to treat organophos- 
phate compound poisoning and another is the use of some of the 
nitrites to treat cyanide poisoning. 

In truth, most medical treatment is symptomatic treatment, 
designed to alleviate symptoms. 

The belief that ingestion of 1080, unless it is emitted through 
vomitus in short order after ingestion, is lethal is not necessarily true. 
The health department in Sacramento, Calif, did a survey of all of 
the known recorded cases of 1080 poisoning in 1976 in response to 
the current RPAR action by the EPA against 1080, 1081, and 
sto'chnine. 

If I recall the flgures correctly — and I apologize if they are not quite 
accurate — I believe there were slightly in excess of 50 percent of 
survivors out of 56 poisonings, which included both accidental and 
suicidal poisonings, so it is not — to put it in more succinct terms, the 
doctor who assembled this data pointed out the risk from aspirin was 
slightly greater in the recorded cases of aspirin poisoning m Sacra- 
mento. I do not mean to be facetious sir, but only to point out that 
many many compounds are toxic and a symptomatic treatment can 
alleviate them in many many cases. 

I would give you a specific case in point recently where water waa 
the lethal factor — an excessive dose of water. 

Mr. Wampleb, Dr. Knowlton, do you care to comment on that? 

Mr, Knowlton. No, sir, 

Mr. Wampler. Let me express my appreciation to each of you 
gentlemen for your presence here and for your obvious contribution. 
Wc appreciate it. I hope you will be available should the committee 
have any additional questions to propound to you in writing at some 
time, or we might ask your professional opinion on any situation con- 
fronting the committee, and that you would share your knowledge and 
professional jut^ment with us. 

Mr. Wade. We would be pleased to do so. 

Mr, DB LA Garza. You have been most helpful. 

The next witness is Mr. Martin Wardlaw, president of the Texas 
Sheep & Goat Raisers Association in San Angelo. Mr. Wardlaw lives 
in Del Rio. 

We welcome you and would be happy to hear from you at this time. 



db.Google 



%. Owrtan and w a i nn of thi ca«rtttM, I m itirtU Nirilw. RntldMt 
of tiM Tani ShMp I SMt blwrt' AtMClatiM «id • fhMp. 9Mt wd cittlt 
rmehir trm Dtl Rio. Taut. 

I Mwld 1lk« to Uk« thit wtortmttr to txprua e«r opproclotlM to tki 
OiilrMii Md Dthtr MriMn for IntnduetiM of K.R. <72S. IhU logltUtltii km 
Introdocod bocauM CongrMt nw^nliti tiwt th* DopireNnt of Intorior Is mt 
carrylnq out tht prodotor contral msnm u diroctod tv tha Pfodttor CoMMI 
Act of 193). Tho T931 Act clurly dirocti thtt • pratoctlvo pndttor control 
pragrw will bo conduetod. A protoctiM progns 1i obMlvttly MCOHory If m art 
to stay In tho shoop and goat builnoif, and anythliw lati 1i UNCcogtabl*. 

Prior to 1971 ■ pretoctiv* prograa mi belnq conduetod In Taxat. To do this, 
a btrffor teM m* ottabllthod turrounding tha thaap and 4Mt raltinq arois of 
UN SUto. ThU MS accon>1tshod by tho ma of 1080 lUtlom and strycholaa drop 
baits. CoyetM atra kIDal bofOra thay raachtd tha ihaap and qoat cooatfT. *iMn 
coyotoi did got by tha bnffar tona, thara Mra onough pradator huntan to tako 
tht taw that sHppod by. nna Mry ti^artant point that auit ba rmmfrtt Is that 
■ shaap and goat aan cannot tolarata avan ona covota In hli ptsturas. ila ha*a 
enough pradators to eontand irith — bobcats, fogcas, and (a sow araas, aaflsaad 
Muntaln lions — without ceyotas. 

It Is vary clasr ta us that tha only «sr a buffer zona can ba afftatlvo Is 
by tha usa of chMlcal toxIctntSi ospaclally 1000. This has baan proMn slaca 
tha ban on 10S0 In 1972. iMwdlatoly follotrin!) tha ban on 1080, an attaa^ to 
Mtntain a barrlar with hallcoptars ms undartakan. It soon bacan avidaat that 
lotarlor had no totantton of pimlng onouqh nonar into tha aaHal huatlag hudgat 
to gat tha Job doaa. This ns tha rati cllnchar — had latarlor raally aantad 
to conduct a protactlva progran, thay Mould hs*a lacraasad tlialr bad*at mirilatly. 
It Is ay opinion that thara fs nat aneu!* noaoy In tha U.S. to taka tha placo 
of tha toxicants. Tha facts aro that In 1971, tha yaar bafora tha ban, chalcal 
toxicants Mda up SOS of tha pradator control praqrw. Swddanly sni of aar caatral 
progran want down tha drain, and thara wa sat! In ratrospact. It It no* a rtJawt 
that tha losn work In tha buf far iom wis koaolng tha eoyota s at a low aaoa* laval 



D,g,tze:Jb.GOOg[e 



M that thev tmn not bothcHnq calve*. Hmnver, It Min't lorn uRtI) tht miAars 
' built up onouqh to ittrt ciintnq loti of uroblM* In th* cm cowntrv. 

I coH htre todiy In fuU supiwrt of H.R. £725 with onlr on* luBOtitotf NHnd- 
■ent. Scctton 3(c) dttcrlbM v«ry Mil what iwit ba Anm, md that If to we nw 
«Hi» possible to control prtdators. It doesn't putter to us how or i^t tmit an 
used IS long es ■ protective progran 1* conducted thit Is as oood at idwt xe had 
before IMS. If It takes the ^tlonil fiuanl. then fine: hooevar, tt Is avitent that 
to 9at the Job d«M. 1080 will ba ra<wfrad. 

Ua, tharafora, support liModlata research on I've. Thfi rataarch irill prove 
that Uiti cheerical can ba used xlthout danger to the afwlronnant. There ts absolutaly 
no enGUse for the Federal qovernaent allovlnq needless losses to coyotes #ien affactlva 
tooU are available to control Uiea. nurinq these critical ttaes, hoM can anjwn* 
Justify the needless loss of one Mat-oreducln? aniaal, laudi less «1tllons. Just ta 
satU^ a (Mil grew) of protectionists. 

Mhlle research is being conducted to discover —or re-dlscovar— needed toxicants, 
every tool available nust be used to accelerate our control progrMi. Research has 
proven that I'n') can be used In the toxic collar Hltbout any hara to anythlno except 
the sacrtftclal lanb and the coyote that kills It. RasMrch further prove* that 
the sheep and goat producers can use this tool anre effecttvaly than anyone else. 
To ba effective, the collar Mist be available at the first sInn of trouble. There 
trill not be ttae to call two or three people and then mU three or few days to 
get started. However, It Is laxirtant to raw^ir that the cellar It aniy a corractlya 
tool and could never ba depended upon to be a nrotectlve control etthod. 

A further supoort the concept of the establtihaant of an ad hoc coNrittae 
to review the animal daMge progrM, This eoMrittee Mnt be nada up of paopla 
■ho understand that protection of livestock is the Purpose of predator control, 
and it flust ba Mde clear to the Deparbaant of Interior and the DepartMMtt of 
Anrlculture that these people will be Involved In planning the coatrot prooraa, 

I would offer only the followlnil recMaendatlon, and that ts on Pane i, 
Ltne 15, strike the period and add 'for the protactlen of Itvettaek,- at protaetion 
Is absolutely necessary. 

It Is tlaa for us to be realistic about the predator control Issut. Look at 
the philosophy of the Interior Deoartawnt and the people uho work in the agency. 
I iHglne that 98S of the professionals working for Interior wtre trained I* wil<l> 
life biology or il>1lar lin es of st udy. It ts ny underttandtng that atilla purtving 



D,g,tze:Jb.GOOg[e 



this Hne of (tudy • person quItt.naturtUy bKOMH prattctlv* of vlldllfS. Qmm- 
qiwntly, th« «nt1r« DewrtMnt of Int«r1or attitude Is one of protecting wlldltfe.., 
no ntter whether It be a Mhoeplnq crane or ■ coyote. 

I ■■ In no My crltlclilnq these dedicated neoole, is I aaree thet eerteln 
Hlldltfe SMclM need protection; hoMver. there ire other species of wlldllft 
frcB iihlGh nen needs protection, and this Is Mherc the conflict comi In: Our 
llyestock nust be protected If they are to yield food and flbar. 

Heat I ask you to consider the philosophy of the Oepartaent of Agriculture 
and its anployeei. Probably ^nx of the l>SM professional it^ff was trained In 
aqrtculture production. Management or econonlcs. This training Is directed tonrd 
the protection of the products raited by the faniers and ranchers... whether it 
be cotton or livestock. It Is. therefore, evident that the phllosoptty of USM 
Is to protect agriculture production. Since ttili Is the case, I sincerely bellov* 
tint the predator control prograai would be nuch *ore effective as a reseenslblll^ 
of the Departannt of Agriculture. This Is certainly not a new concept, as the 
orlqtnil liH of 1911 placed oredator control In tarlcuTture. It should alio 
be noted that lomedlately followlnn the Leopold Report In 19«S Senator John 
Tower of Texas Introduced legislation >ih1eh would have noved the control w >r m 
turn Interior to Agriculture, 

There are many areas which I have not even attenotad to cover. ..losses to 
predators, estlMted amount of sheep and qoat production In Texas without predttort> 
and the list goes on and on. "^ost of this Infonsatlon wtI1 be covered by otfwr 
witnesses far batter than I could nunaoe In the tiM ■« have. 

%. Chalman, I houIH anain like to thank vou and the n«rters of the coiHlttei^ 
for your concern for the sheep and goat Industry as evidenced by the Introduction 
of H.R. G72S. and I would vnta the passatw of this wch-needed legislation. 

He In agriculture are being asked to produce nore and more to feed an ewr- 
qrowlnq nation. Livestock producers nust heve protection frea nrvdaton If we 
are to acconnllsh this task. 



D,g,tze:Jb.GOOg[e 



241 

Mr. DE LA Garza. Thank you very much, Mr. Wardlaw. 

Mr. Wampler? 

Mr. Wampleb. Thank you, Mr. Chairman. 

Mr. Wardlaw, I want to thank you for your statement. I assume 
that you were in the conunittee room this momii^ when Mr. Howard 
made his presentation. 

Mr. Wahdlaw. Yes, sir. 

Mr. Wampler. You saw his slide presentation as well as heard his 
testimony. Was that a fair and accurate presentation, do you think? 

Mr. Wahdlaw. Yes, sir. I beUeve it was. It painted the picture 
prettv well and I thought the slides were excellent. I thought they did 
a real good job of showing what our situation is. 

Mr. Wampleb. You think it was a fair and objective recital of 
the situation that Mr. Howard was faceil with as a producer and what 
others in your area would be facii^. Is that correct? 

Mr. Wakdlaw. Yes, sir. The only difference is that in our part of 
the country most people would not have put up with what Mr. Howard 
has put up with. They would have gone out of business a long time 
before they suffered the losses he has. 

Mr. Wamplbk. If I remember correctly, Mr Howard testified that 
he was prepared to liquidate his operation until he learned of the 
toxic collar. That kept him in business, or at least caused him to 
reconsider his earlier decision to liquidate his herd and close down 
business. Was that not correct? 

Mr. Wahdlaw. Yes, sir. I can certainly understand his position 
on that. 

Mr. Wampleb. I want to thank you for coming. Your testimony 
is helpful. As I say, we are sympathetic, but you came for more than 
sympathy. I know that. We will carefully consider your testimony and 
tnat of others who have testified. 

We thank you so much for your patience. We appreciate it. 

Mr. DE LA Garza. Mr. Wardlaw, you live on tne Mexican border 
and are acquainted with the ecomonic and labor situation down there. 
Do you know of anyone who has attempted to being a sheep herder 
or someone to work on a ranch from Mexico that has been able to 
easih" bring them in? 

Mr. Wardlaw. No, sir. That cannot be done. As a matter of fact, 
I have friends in Mexico that have tried to get herders. There is a 
lot of country in Mexico that could be used, similar to the brushy 
country we saw in the slide program. They cannot even get herders 
in Mexico. 

We are in a whole lot worse shape than they are on labor so we 
have to have loose grazii^ pastures. 

Mr. DE la Gabza. Mr. Wardlaw, we thank you very much for being 
here and for your patience in awaiting your time to testify. You have 
been most helpful and we certaiidy appreciate it. 

Mr. Wardlaw. Thank you. 

Mr. DE LA Gabza. The final witness is Mr. Jim Barron III of 
Spur, Tex. 

We welcome you and would be very happy to hear from you at 
this time. 



D,g,tze:Jb.GOOg[e 



Hy nana la Jia Barron III. I an a rancher fron Spur, Tenaa 
and I aerve as Chairman of the Anlstal Damage Control Subcomiiltta« 
of the National Cattlemen's AsBociation. 

1 an testifying for the national Cattlemen's AeBoclatlon, tha 
Public lisnds Council, and the National Grange. 

He support bill H.R. 6725 with acma changes. We don't think 
it goes far enough. 

Depredation on livestock and on other agricultural product* 
is a far more serious problan than moat people realize. Perhaps 
it is underrated because the Fish and Wildlife Service has conaia- 
tently underestinated , as well as misunderstood, the impact of 
dapredation upon agriculture. 

While depredation has caused many livestock producers to go Out 
of business (with prime land being converted to nonagricultural 
uses) depredation actually has more of an economic Impact on consumers 
than on productora. In the end. It is the consumer who pays for 
predation in higher prices for agricultural products. 

It is ironical that at the same time the President is asking 
all of us to help keep prices down, his Secretary of the InterioE 
is pursuing a policy which will push neat prices up by several 
hundred million dollars a year. Maybe the Secretary of the Interior 
needs to be recruited for the war on inflation. 

The final environmental impact statement On the program to ccntcol 
nanulian predation in the Western states esttnates that •ach predators 
killed about $40 million worth of livestock in 1977. That loss 
increased neat prices by $102 million, the statement says. But 
these cost figures are outdated and the livestock loss surveys 
on which they are based are not the latest and beat available. If 
more cooiprehensiva loss surveys were used and if the value figure* 
for livestock losses were updated to tf>day'B higher price*, tb* 



D,g,tze:Jb.GOOg[e 



econamlc impact on consuiters snd producers from coyote predation 
juBt in the Hest would greatly exceed $300 million a year. 

This does not take into account the secondary economic impacts: 
the multiplier effect on other dependent segments of the economy 
and the harassment or injury of livestock not actually killed, 
as well as the considerable costs incurred by the operators in 
trying to protect livestock fccM predators. 

By banning or restricting practically all of the effective means 
of predator control now being used. Secretary of Interior Andrus' 
new policy could double this econcoiic impact on producers and con- 

Theae are just the coats of predation from mammals in the 16 
Western states. Predation frcn coyotes and other mammals is increasing 
in other areas of the country. Fran Iowa to Maine to Florida, 
nearly all states are reporting heavy livestock losses to coyotes 
and dogs. 

Dr. C. Kerry Gee reported that 245.5 million head of cattle and 
calves were lost to coyote and dog predation in 197 5 (Journal of 
Range Management, Harch, 1979). At that time the calves killed 
were worth $31 million but today they would be worth more than two 
times that in market value and three to four times that figure In 
cost of production value. In 1975, nearly 71 million head were 
lost in the southeastern area of the United States, about 19 million. 
in the Horth central states and over 33 million in the Great Plains. 

Dr. Clair B. Terrill of the U.S. Department of Agriculture 
(Science and Education Administration) in a study of sheep and lambs 
losses over the last 21 yaacs conolnaively deaonatratad that preda- 
tor damage haa expanded both eastward and southward throughout th* 
U.S. and losses have steadily increased aince the changes in the 
federal predator control program in the mid 1960 's and since the 
Executive Order banning the use of toxin* to control predators. 

Dr. Terrill says that the value of the sheep and lamb losa to 
producers has risen fron S25 million in 1961 to $9S million in 



D,g,tze:Jb.GOOg[e 



1978 and he states that prodatlon is a major factoc In the dscliiM 
of the industry since 1960. *0n the average,* ha says, *iiBt 
returns could be doubled, or more, if predatora were controllad.* 
So far, we have been discuBslng the effect on livaatock from 
pradation by mammala, mostly the coyote and dog. But moHaals, 
including the coyote, alao cauae crop danages. And if we consider 
other types of predators, auch as birds and rodents, the economic 
Impacts on fanaers> orchard operators and conaumerB run into addi- 
tional hundreds of millions of dollars. Predation la a aerioua 
agricultural problem by any definition. 

That is why the entire agricultuzal coanunity is diatorbed by 
Secretary Rndrua" irrational policy concerning the weatem animal 
danage control program. If the animal damage control program ia 
going to ignor the needs and value of agriculture ...If It la to 
be based on emotion rather than on scientific data, then It la not 
aerving the intent of the original 1931 Act establishing the program. 
Secretary Andrus* order banning further reaearch on the efficacy 
of the predaclde lOBO juat when the acientlfic researchers tail ua 
that all evidence points to its safety is a fom of anti-intallae- 
tualism. He, In effect, ia saying, 'Don't study It tuxthac, w* 
are afraid you are going to prove it aafel" 

The only excuse the Secretary gave for thia action is that auch 
reaearch ia "controvsralal. * It ia controveraial to seek tha truth? 
(In a rwant inaating, the Secretary indicated that he was not 
familiar with the results of the research already done on Coqiouiid 
lOBO.) 

Hr. AndruB also banned denning and reatricted aerial huntliig and 
the use of traps, also on the grounds they were 'controversial. * 
Hitb the eliminaticn of toxic methods of control [sens yaaxs 
ago) , these methods were about the only vestiges of predator 
control being used. Without auch metboda there is no sffaGtlva 
control of predation. 

The Secretary's "Alice in Wondarlai-l" policy is t 



D,g,tze:Jb.GOOg[e 



eoErective control using non- lethal, non-capture raethods and to 
disturb only offending onljials. The livestockioan is supposed to 
BCSEO off tha coyote. Not just any coyote, Just the one eating hia 
livestockl I *Dppoae If the rancher acarea the coyote badly there 
will be another Secretarial policy isBued. 

The suggestion by the Secretary that husbandry techniques and 
providing sore extension services can take care of the problem illua- 
trates the woeful lack of understanding that he and the Depactaent 
Officials have concerning ranching in the West. Much of Western 
livestock grazing covers millions of acres of open range, both 
private and public. Can you Inagine stringing millions of miles 
of electric coyote fences accoaa thla vaat expanse or gathering up 
53 million ecus and 15 million eheep and putting th^i into barns 
or sheds every night to protect them frcni coyotes. Depredation is 
so widespread and unpredictable that the fact that the Secretary 
would even suggest fencing, shedding and shepherds as practical 
solutions not only boggles our minds but insulta the intelligence 
of the acientiato and professionls in this field. Sone of tha non- 
lethal methods will provide more than extreotely limited control. 

I note that several predator researchers are scheduled to 
testify during this hearing. I am confident they will speak in 
more detail on the research on ccupound 1060 and on the inpractl- 
cality of Mr. Andrua' nonsoientlf io policy. 

As far as expanding extension information to ranchers is con-..:- 
cemed, the Extension Service says, in effect, that they are already 
diapenaing all they know; there is nothing new without further .. 
research. 

In prcroulgating his policy, Secretary Andrus choose to ignor 
the professional advice of his own experts and to bo« to the pres- 
sure brought by certain indlviduala on the Council on Environmental 
Quality who have no special knowledge of the livestock industry or 
of predator pBobleois. 



D,B,i..ab,Google 



Perhaps another clue to the HOurce of his policy la tba fact 
that he pieced Ms. Cynthia Hllaon in charge of seeing to it that tba 
prograa was Implenented. Hs. Nilaoti, besidea being on Andnu' 
staff, is a Vice-President of the Animal Nalfara Institute. 

Apparently — since th«rs la no aoientlf io basis for any of his 
conclusions — bis policy la based on sane kind of selective coao«m 
fOE a certain species of aninals. The saae concern Is not ahoixn for 
the calves and lambs that are disemboweled by ooyotes. As a matter 
of fact many coyotes kill or injure livestock not for food but 
Just for the joy of it. 

Of course coyotea have a cole in our ecoHystem and they should 
not all be eradicated. (They couldn't be even If we tried.) But 
awn has changed the ecosyBteim by his settlanent and we have found 
that many foma of wildlife must be managed to maintain certain 
values including wildlife values themselves. Deer populatiooa, tor 
example, are managed for the welfare of the deer thenaelvea.- Wild- 
life specialiata would acoff at a non- lethal, non-capture policy 

Predators likewise should be managed on the baals of the best 
scientific information and research available so as to maintain 
certain of society's values, includinc) the values that humans find 
in eating food and wearing clothes. 

Rot only is It not conducive to good health for humana to 
stop eating food and (especially In scrae temperatures) to stop 
wearing clothes. It ia unpleasant and often fatal to contract one 
of the many dlaeasea spread by predators (rabisa, plague, and a 
long list of lesaer-known diseases] . 

Predators also transmit diseases to wildlife and livestock. 
Millions of dollars are being spent to eradicate the disease bra- 
oellosis with little success because a recent study shews that as 
soon as brucellosis is eliminated fr<m an area the coyote carries 
it back. 

We believe that it ia necessary to get the Animal Damage CcmtroX 



D,g,tze:Jb.GOOg[e 



Program back to a sound scientific and factual basis. We don't thl 

the program should be run by an official of the Animal Welfare 

Institute, nor a cattleman or a sheepman or a politician who believ 

that 'know-nothing Ism* is better than the truth. If the pcograia 

involves "controversial" issues, that to all the more reason why 

the administration of the program should be transferred to the 

professionals and to an agency that vill seek the greatest good 

for the greatest number. 

We and a number of other organixations which I shall mention 

later have agreed that the Animal Damage Control program should 

have the following objective) 

Development of an animal daatage managenent program 
that effectively mitigates agricultural economic losaes, 
prevents human health hazards caused by predators and 
other animalB, protects wildlife resources, and main- 
tains agricultural lands for agricultural production. 

To achieve the scientific objectivity and integrity that this 
program should have, we recommend that the Animal Damage Control 
Program and .all research on predators be returned to the Depart- 
Dent of Agriculture where the ADC program originally resided. 

The Animal Damage Control Act mandates the suppreaaion and 
control of animals that spread diseases and animals that are injur- 
ious to agriculture, horticulture, forestry, etc. 

The Department of Agriculture already conducts predator re- 
search. It has jurisdiction over the Extension Service. It has 
the expertise and knowledge to evaluate the extent of predator 
damages to agriculture and what control methods are practical, 
feasible and safe. It has long been involved with animal health 
and diseases spread by animals. It is familiar with wildlife 
issues since most of the nation's wildlife are on farm lands. 

■The U.S. Fish and Wildlife Service which now rund the ADC 
program admits frankly that "in light of the Service's primary 
responaibillty of conservation and protection of fish and wildlife 
resources," it has chosen to twist the meaning of the Animal Daioage 
control statute. The ADC Act is no longer appropriate, the Service 



D,B,i..ab,Google 



•ays, in light of changed attitudes and perspsctivea <p. 2 t 4, 
Pinal EI8 on ADC program in NaBtem U.S.). 

Therelore, we believe that the ADC program more properly falls 
under the juriadietion of the Department of Agriculture which is 
more familiar with agriculture and with consumer needs and safety. 
Such a change may help to bring nore objective professional Judgemsnt 
and reaponsibility back into the conduct of the program. It la 
obvious from Hr. Andrua' recent policy that the Department of tba 
Interior will overrule any sensible and; practical Eacommendations 
from personnel In the Fish and Wildlife Service who recognize agri- 
cultural needs. It la apparent that Interior is not able or willing 
to carry out the balanced animal damage control and research program 
outlined in bill R.R. 6725. 

He suggest that R.R. 6725 be changed to provide for such a 
transfer. The legislation should direct the Secretary of Agricul- 
ture to develop and Implement the program and control methods 
specified In the bill; and also that the Secretary of the Int«rIor 
should be directed to cooperate with the Secretary of Agriculture 
in carrying out the program on public lands administered by Depart- 
MOit of the Interior by utilizing lethal and non- lethal methods and 
by using tc»ctcants such as Compound 1080. 

It is important to realize that much of the land in the West 
is suited only for livestock grazing. Other agricultural pursuits 
are not possible. If such ranchers go out of business because of 
Andru«* hard and fast policy, they have no other alternative mean* 
of mefclng lnc6mes. 

The following joint statement oppoaing Secretary Andrua' anlaul 
damage control policy and supporting transfer of the program to the 
Department Of the Interior haa been endorsed by the National CattlB- 
men's Association, Public Lands Council. National Grange, National 
Mool Growera Aasoclation, National Famera tmion, National Turkey 
Federation, National Animal Damage Control Association, Nattooal 
Association of State Departments of Agriculture and the National 
AQrlcultural Chemicals Association: 



D,B,i..ab,Google 



He believe that the impleDentatlon of Secretary of the Interior 
Cecil Andrua' directives of November B, 1979 regarding the Animal 
Damage Control Program (ADC) will result in greatly increased 
livestock losses due to depredation. Such losses, in tunx will 
Increase consisnar costs and have other undesirable eeemooic, 
social and environmental effects. 

He find that the Secretary's directives are not based on 
scientific advice or established facts. There is no scientific 
basis for his decision to ban further research on the predacide 
*1DS0* and the use of the practice of "denning;* nor is there 
any acientific or practical reason to restrict aerial hunting 
and uae of traps to control predator numbers. 

There also is no research or evidence to indicate that non- 
lethal, non-capture methods of predator control could provide a 
practical solution to the depredation problem. -■■-■■ 
such evidence, such methods should n~" "^ ~ --^-.- 

Current methods of predator control should not be abandoned 
or restricted unless and until it can be demonstrated by scien- 
tific research that there are feasible substitute methods available 
that will not result in increased livestock losses. 

Furthermore, it is not reasonable to claim, as Secretary 
AndruB does, that a cut in the ADC operations budget will provide 
■the sane level of livestock protection." 



Therefore, we jointly support the development of an aninal 
damage management program that affectively mitigates agricultural 
economic losses, prevents human health hazards caused by predators 
and other animals, protects wildlife resources, and maintains 
agricultural lands for agricultural production. 



Since the Department of the Interior apparently is unable or 
unwilling to implement such a program, we reconmend that the 
administration of the ADC program, and predator research, b« trans- 
ferred to the Department of Agriculture. 



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250 

Mr. Bakron. Mr. Chairman, along with Mr. LeonanI Noh, I have 
been coming; up here tor 8 yeai-s trying to achieve a workable program. 
In that 8 years the lifestock industry lias lost hundreds of thousand 
of animals. We feel that we have made the environmentalists hundreds 
of thousands of dollars. With every tittle spat that developes they have 
a newsletter };oin{i out to their constituents asking for more money. 
I will introduce a copy of such a letter. 

That is about all that we have accomplished. We have received 
many promises. Our hopes have been up many times. 

The results of this hearing, the efforts of the participants, and the 
effect of your legislation, sir, is the grandest hope of achievii^ a work- 
able solution that we have ever had. I thank you. 

Mr. DE LA Gabza. Thank you very much, Mr. Barron. 

Without objection, the two pieces of material which you intend to 
send will be included in the record at this point. 

[The attachment to the statement is held in the subcommittee file.] 

Mr. Wampler. Mr. Barron, I want to compliment you on a very 
comprehensive statement. I aj^ree with most of what you had to say. 

You alludeil in your statement to the fact that the Secretary of the 
Interior did not seem to want to continue this basic research on 
predacide 1080 because it was controversial. You know, if the Coi^ress 
of the United States were only to act on those measures that were 
noncontroversial, I doubt that we wouhl get too much done. Maybe 
the country would be better off if we did not do so much around here. 

Mr. Barron. I agree. [Laughter.] 

Mr. Wampler. The point is that here is a major public policy 
determination that has to be made. Somebody is going to have to 
make it. Under our separation of powers arrangement, we have three 
separate but supposedly equal branches of the Federal Government. 
The Congress is one of those three branches. 

We are the ones that are chained under the Constitution with the 
responsibility of legislating and it is the constitutional responsibilitv 
of the executive branch to administer and implement the law, I thinK 
that we are going to have to have some input from the executive 
branch. 

I hope we will have the opportunity to ask Secretary Andnis as a 
witness before this committee his reasoning behind tne decision. I 
have my own opinion. I think you have reached some conclusiona 
and I do not fault those conclusions. 

But the point is that we want solutions. I am not lookii^ for a 
political issue. I think there are enough of those floating around in 
other areas without having to make a political football out of this. 

As I view it, this is a question of the survival of a vital sector of our 
agricultural economy. I have nothing in the world against coyotes. 
On the other hand, I think we have to reach some reasonable balances 
and tradeoffs. I just do not feel that we have reached them up until 
now. 

I commend you and others for your persistence in coming back 
year after year. I know how discouraging it must be to you. I just 
want you to know that there are some of us who are listenmg and are 
sympathetic and ore going to do our best to give you some legislative 
relief. 



D,g,tze:Jb.GOOg[e 



251 

I cannot assure you of that. I wish I could. I wish I could just wave 
a magic wand and this problem would be solved. Unfortunately, it is 
not that simple. 

Mr. Barron. We never tried that before. 

Mr. Wampler. There is strong feelii^ on both sides of this. I do 
not question the sincerity of anybody for the position they have taken. 
I question the judgment of some but not their sincerity. 

Our job, as I see it, is to try to fashion legislation that will address 
itaelf in a meaningful way to the concerns that you and others have 
expressed here. I pledge to you and others here that I will see if we 
cannot pass some legislation through the Congress that will at least 
enable us to move forward to find answers and solutions rather than 
seeii^ the industry continue to be pushed down and back. What will 
ultimately happen, if that occurred, would be the demise of the sheep 
and goat industry in this country as we know it today. 

I appreciate your sincerity and concern. Let me assure you that 
we will be doii^ our best as quickly as we can to move this legislation 
through this committee and hopefully through the Congress. 

Mr. Bahron. I appreciate your time, sir. 

Mr. DE LA Gabza. Thank you very much. 

This concludes this phase of our hearings on this legislation. The 
subcommittee will stand adjourned subject to the call of the chair. 

[Whereupon, at 3:55 p.m., the subcommittee was adjourned.] 

[The f oUowii^ material was submitted :] 



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suTDmn OF am. dice cheket, a tEnxsmiant n cowans 

FUM THE STATE OF WTOMIK 

Me. atAlnaan, I want to oeMMnd you and tha othar Mnbara of 
tbe Subcconlttaa for holding thaaa haaringa on tha pradator problaa. 

Mhila doing aoBie raaearch for ny atatament hera today, I had 
occasion to look through the tranaecipt of Eiald haaringa hald tn 
Idaho and fiyoming back in 1973 by the Senate Interior Subcooaitta* on 
Public Lands. Thoaa heacings followed Praaident Nixan'a 19T3 ban on 
tha uae of toxicants, and the sheepmen who testified back then wara 
confronting tha nana pcoblam as the producers who will appear bafora 
yon this week. They had just been deprived of an Important part of tha 
naans used to protect their herds frcra predators, and they were very 
oonoamad -about tha future of their industry. Aa it turned out, 
they had good reason to be concerned, for many producara have gone 
oDt of business since 1973 and loaaaa to predators undeniably hav* . 
been a factor in the decline of the sheep industry. 

nie Industry was told at Che time toxicants were banned in 
1972 that there would be an extensive progran of research and tasting 
to find new, non-lathal and selective means of preventing livestock 
losaea to pradatora. How. eight years, millions of raaearch- dollars 
and snny thousands of dead aheep later, they are told by Secretary 
AndruB that still nora reatrictions will be imposed on tha control 
program and that fswar tools and methods will remain available, but 
tbere will ba more eittensive research and testing to find new, non-letbal 



D,g,tze:Jb.GOOg[e 



and aelective meana of praventlng livestock loBses to predators. For 
those producers who have managed to stay in business these past few 
years, there must be a strong feeling of deja vu. 

Mr. Chairman, no one quarrels with the objective of developing 
non-lathal predator control methods. I am certtiin the livestock 
industry would love it if such meana could be developed and eflecttvely 
used. After all, such an eventuality would give thema non-controversial 
way to protect their livestock, which is what it'j» abl about! and they 
would not have to cone to Congress seeking support for an effective 
control program. But we aiinply aren't there.yet. land whilie we should 
continue to work toward that goal, we muse . insureithat in ,the 
meantime, the proper variety and combination of contcol methods remain 
available bo that the industry can surrivev '.-.. 

The government is obligated by specific statute to protect 
wildlife and domestic livestock populations from predators. I am 
deeply concerned that the Interior Department's new predator policy will 
put the government in the position of failing to meet its lawful 
obligations. The policy conmits the government t<j« stepped-up effort 
to find more benign and leas controversial ways to deal with predators, 
and that ia admirable. But at the same time, it takes away msre of the 
tools and methods now known to be'effective in controling predators, 
and by so doing, it leaves the livestock industry vulnerable to even 
'greater losses, and, therefore, greater economic jeopardy. 

One of the things that has intrigued me about ^Interior Secretary 
Cetill Andrus' new policy is its variation from the eventa and studies 
thit' preceded' it, &nd troa the reality of the - eituation . 

IV seems that the genesis ofift-he events which.brought ijs here 
today was in 1977, when the wool growers sought Secretary Andrus' 



db.Google 



In raducin<i pzvdatOE losaai by Inprovlng tha' •fEactlvuBBB 

>'>«f tM eontlrol progru. Than, ai nov, tha Industry n* auttaring 

. alqiiif leant loaaaa, and it aakad tor the BacTVtary'a help. 

. ' Aa a raa'ult of the r*qu*ati an adviaory comilttaa wai 

■ppotntadi public hearing* Hera held, and an in-dapth atudy h«« eondootaa 

hy tJieD.S. Piah and Mildlifa Service ohicb lubatabtlatad th* azlatanea 

of ••rloaa loaaaa. aat forth the problena aaaoclatad vith tha coBtrol 

proqraa and diaeuaaed tha conaequencai of varioa* optlona tor ravlatng 

*h* objaotlvai ot tha prograa. . ■ e.i. 

■ -v. Iltat atady waa than followed by additional rsMarch and 

aolicttation of agency and citizen oqonunta which raiultad in tha production 

of an axta naive draft environmental Ingiact atatamaDt, and, later, an 

ev«n uWa aitanilva final environmental lapact atataBaot. All ot 

theae dbcunehta, vhila diacuiaing a variety of apprbaehai to tha problaa, 

recognliM in great detail the eniatenoa and aagnituda ot tlia problaa 

and the ifaed tor corrective action. And than, in Bovaibar of Utt 

year, cadM tha Eacratary'a policy atateaent redirecting the tocos of 

Itbe federal prbgraD away tron control ot predatora aad toward Icoig-rBiiga 

caaaarch'iin nori-lethal waya to prevent predator donage in the tutura. 

Thar* ll'n&Uilng in the new policy to help now with tiie exiitlng 

pr«d«tor '¥t^l*B. In tact, it dlniolahea the niuiibar"and klnda of control 

c^tlonri' OMt have been availabla. Qlvan theae reaulta; tha livMtOOk 

induatry milt feel Ilka it haa baan vlctiniiad. ' 

Hie new policy aounda good, but given the tact that the govanaant 

haa already devoted aany yaara to the eame kind of rataaroh anbraoad „, 

by tha Baoratary with Halted result*, and rscogniilng that it will taJia,^. 

aehlava hia' goal. It it'* achievable at all, 
d to do In the aeantlaa? The 
e govarnaent ' • reaaardi reaulta. 



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ThB Sacrataiy « « «■ ■ to luva igaoE*d th* mibstuitlal. body of 
infomtloD (rathetttd during Um (tody procu* ud tlw fnwnditlon 
or naiiy «ho ooafaDMd, loelodlng •ow In bla own afucy a^ the 
■clantlflc ccMwnlty, In oidar to aabraea tha i ■iiriiMaiiilil liiin of « 
■In^ls .«9«ncy ~ tha Cooneil on EnvioriuDPntal duality. If 
th«;CqaK:il'* coMiuit* during tba anvlioruisntBl impact atafint pEO«M« 
to tha SacEMary-a final policy, tha alailarity ia otnrioaa. In fact, 
much of tha policy paiallala vord-for-word tha CH'a i ■im^iiilal Iniia 
, . Tha tcoubla with thia appioach, Hr chsiiman, ia that CKI has 
conaiatantly rafuaad to acknoolcdge the nality and amarity of 
the pEadatoc probUai taoina tha livaatoek iaftaatiy. 

Tha 1^78 riah and Wildllta Sanrica study poiata out that 
the .total, dirafit aooDaadc loaa to abaap and oattla prodnoata in 19T7 as 
a raaulf:, of ooyota pradationa waa about 139 Billion. In addition, tha 
aatinatad paga^t^va lj^>aot on oonatanra daa to coyote activity waa 
$98 Billion for boaf and S4 ■lllioo for Uab daring tha aam yaar. 
We can aaauM. given tha tlaa that baa paasod and tha aarloua problaaM 
that have baaat our aooDcav alnoa 1977 that thaaa loaaaa ara avan aora' 
aubataotial now. Tha problaa ia emI, ifa continuing, end tha 
govrfmnant can atody new awthoda all It want*, but in tha ataaBtlaw, 
a lot of ooyotaa ara going to oontlnaa to eat a lot of abaap and goata. 

Aa for the contzol prograa that haa been oondootad thaaa paat aavaral 
yaaia. It haan't [^avantad all loaaaa, bat It eartainly haa radaoad thaa 
frcn wt^t would have ocouxEad without control aotlvitlaa. Baa thla 
progr^ Jaopaxdiiad predator apaeiaa7 hcoording to tha Flah and 
Hildlilji atu4y','if talk not. The atudy ooneludaa that rtbare are no 
aigniflcant advarae Intacta on wlldlifa popiilationa raaultlng froa ' 
the predator daaage oontrol progian aa now conductad.* 



D,g,tze:Jb.GOOg[e 



It point* oot that ■■ iaall p*r omit of totkl. noyoto popolatlau 

■xa takao oaeb y*«r,' bat that thara i* *no throat tA ooyota 

populatloai In any aignlfioant aroa of tha llaat.* It also eonolndas 

tlut Dcni-tax9at inpaet 1* llaitad to *lnalgnlfle«nt parcaBta9as of 

■paoiaji tlwt>,*ra abundantt' that thara ha* baas only oba^ oa«a whara 

tha ADC pregMB' Inadvertently aftactad an aBdaBfOEod anlaait and that 

tha only pro(i«K-rl*k to buaiaiia !■ to pllota «tio 'ingaga In aailal banting. 

Bat daaplta thaaa tindlnga, tha Svcratary optad for a polloy 
Hhleh, aaoag othar things, 'Kill racognlie tha- laportanca of pradatoca 
to natoral •ooayataaa,' and advocataA i^ncglnq llvaatoek In moh a <iuf 
that thsy Kcm't Ba al^oaad to pradatoii. 'In acaw eaaaa, a ratvTB t« 
traditional iMthoM (auoh a> hardaEa) ihoald ba sarionaly oonaidorod 
and onoonragad,- tha Seotataiy notad. In m—mia^ Ignmanoa of tha fact 
that hatd<Ka aia and alwaya havo baan uaad to tha axtant that thay oan 
ba fonnd, and witfcMt racognltlog that tha polioioa of tha U.S. Dapartaant 
of Labor hava Bade It najtt to U^ioaiibla for llvaatook produeara to 
obtain hfedara^iT^r- i" '■'■' 

nw Saoratary alio aac tit to oaaaa any Eorthar raaaareh on tba 
obaaloBl eeapODDd lOSO, iihile poEBlttlng continuad raaaaroh on othar 
toaloant* 'that do not hava aacondary affacta, ara aalactiva and hi^aaBi' 
daaplta tha fact that thara ara no other known toxioanti that hava ban 
aubjaetad to tha ri^orou* and aatanalTe Eaaaarob and tatting oo^notad 
to data on 1080, and daipita the fact that raaulta ao far hava abowa 1010 
to ba tba noit raaponalva, and aalactiva tool In eoyota control that la 
aval labia. 

By banning loao caaaarch, tha Saoratazy ignored tha r»cp— nditiena 
of hla cwn rlah and Nlldlifa Barvice Director, I^nn Graanwalt, Mho 
urgad acoalaratloa of lOSO raaaareh on ahioh tha I 



D,g,tze:Jb.GOOg[e 



tiBB already apant Billion* of dollaiB. Indasd, th* Flah a 

Servic* Ka«, at tha tlm* of the Saerotary'a dKiialon, pcaparlng to ladi 

EPA approval for reglatration of tha chaaical for aipartBantal ma. 

Currant law raquirai that EPA could grant such a requaat only if thara 

vaa lubataneial new avidence nuterlally affecting the original dacialon 

to luapand and cancel 109O reglBtration. Given ehaae aaCeguarda and 

the faTorable reaaltB to date froa 1080 raaeareh, there ta no juatiflcation 

for taiBlnatlog thi* work. 

Mr. Cbalrman, I hop* the aubcodoittae . and ultiHBtaly tha Congraaa, 
will aa« fit to anact the lagialatlon Introduced by yourielf and Mr. 
Looffler to afford the liveitocli Induatry bobc continued protection 
sgainat predator Iobbbb. 

andar a lav auch oa you prapoae, the Secretary could continue with 
h-a raaaarch on dod- lethal wayB of preventing predator loaaea, but in 
the BeantiiBB, thara nould be a damage control prograii that hopefully would 
enable tha Induatry to aurvlve and proaper until auch tiae «b tha 

Aa I undaratand the pending lagialatlon, it would: 

Mindate a joint progran by the Departnanta of Interior and 

t by predator a by permitting the 



luad raaeareh on chenical toxicanta, including 1080, 
aentally praCarrad lethal and 



AgricBltura to cont 


ol damage 


uae of both lethal 


nd non-le 


toxtcaota. Inoludin 


108D, 


require con 


Inuad raa 


.--. :9phaalB on ae 


active and 


non- lethal toxicant 


I and 


— require app 


lad field 




ctioaa. 



h on non-lethal tachnlquaa and 



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Dndar thia l*giBlation, th« r«fl«aeoh aMbraoad by tlM 8«orauxy 
would nova- totvsrd, but in th* tMontJjM, tha Induatrr would hav* an 
effaotiva control program, niat, Mc. Otalman, la aaaaattal, and I 
pladga to do all i can to halp aacuce tha anact«a(it of tha 
Da La Garxa/Uwfflar bill. 

Thanh you for thla opportunity to coDtnent. 

I«tttt«ttt««ttttttt 



D,g,tze:Jb.GOOg[e 



, ST&TS OF sni hkhco 



■Codic* eooducted Mo jaata aftar Cha rSBmal of tmieanCi bj 
Bzacutiva Accion, indlcac* that aimual abaap loiaa* to cojotaa aaat-wlda in 
197& aBOuncad to about al^t parcant of cha laA crop and Cao and ooa-balf 
pateant of tb* adult hard, eoatini prodoc 



producer* diaeoDtinaed ibaep prodaetloa ii 
wera aran hl^iar, abowing a loaa of about 
laaba) of tha Imb crop and cbraa parcant 



■•r* tha aajor raaaon that abaap 
Utah and VyvMiag. >a« Mailco loaia 
1 palcant (apprazlaatalr 66,00 
[14,000 haad) of tha adult bard. 



Haw Hczico iliacp producata have vltnaaaed 
bara ainca 1959. Tbii not only i^taota oi 
•uui]r eosaultiaa tbcouihout tba atata ahoi 
livaatock induatty. Baduetiooa of tbi.* ai 
raaly Iv" 



SO parcant daclina in ahaap mm- 
ba abaap induatry, but alio on 
•conoaiaa nlj haavlly oo cha 
nt to cha abaap isduatrr tboa can 

laavily on tha alraadj dapraaaad acoonay of Haa Meiica nhoaa 

I* ranked 43Td In tha laCion. 



lllioaa of acrai of graalni landa, nany undar tha jurladicCloo of tha Dapart- 
mt of Agricultura (DSDA) and tba Dapartaant of tha Intarior (DSDI), ara in- 
■ith pradatory anlaala, aapaciallj cojotaa. A* a raiult. It Ii ottan 
■ibia for producara to graaa thair atock on thaaa landa. Thaia ('■■^■>t 
■nda could ba nora affactlvely oaad and graat financial losaaa coald ba nlti- 
itad if livaatock producara vara providad a aora atfactiva progTsa to control 



I do (upport the objactiva of H.l. (725 to davalop and carry oat a balancad 
aniiul daaaie control progr^ that effactivaly ntiliaaa both Utbal and noa- 



D,g,tze:Jb.GOOg[e 



lethal cant 
■hould ba perall 
taaiimul aaparl 



and tba DSDI. 
itac«> becaoaa 
tor an eftecciva 

tadaral Uc 
ia Urgely 



raa. I alaa balir 



I that pravaativa coatrol Baawirai 
■lary ■■ daterminad by tha local pco- 



coatTol progtaaa, eapacially those that utiliaa Cosi- 
:icall7 Ilaltad on landa undai tha jurtadUtioa of tba OSU 
Thl* proanta a ••riou* problaa ia Na« Haxico aod aoit aaataia 
ideral, acate and private land are iaceraiagled. TO prorida 
pro|raa, I augceac chat H.K. 671S include laa(uafe that 
:t« ■ balanced aod effective pro|Tia on all land including 
Wlchout thl* type of control, an aoiaal daaage eantrol prograa 



Ihank jou for the apportunity to provide wf eo«aeat* 



1 thia iMportant iaao*. 



D,B,i..ab,Google 



Wildlife Management InstitutE 




p 



f 



bla E. (Klka) de la Caria, Cliairu 
ilccea oa Departaeat tnveaClgatlon 
rslght and Reaearch 



a that It vould fa 



d for 






. 6725 Hould atilft 



ulcrr. 

Cher Cfam the activity pi 

■ooe predator control relponal 
Ptedatoi contiol 1 
lity In an agency ( 









jirobably alosya 
■aponalble for coi^rclal 
ipecta vlll be Incanalfied and 



icy helog uvcd ti 
the leglelaclva 



You ahould undetacand thaC the laaclcuce la not unolter. 
ise of lOBO. Very recent reaeacch naulca reportedly In 
i:aa be a highly apeclflc polaon for coyote conttol tAen i 

collar being devfiloped nay b« aBpaclally affective. Con 
that the application of lOBO should ba ruled out couplet 

On Che other hand, conpound lOSO, without queation 
too Hide and encourage abualve use of the compound. Wildlife : 






D,g,tze:Jb.GOOg[e 



ecccd idvirielr and public a 
erior Sacncarr Andnw hai h 
trol CBlla for ending lOSO r 



nduaciy vlll ba aervei 

he DCH federal policy. Should 1 

■ ahould Hork tOBettaei 



suld latanalfr- toi 
atrov«r(lal aod arouaaa 



nata of both olldllfe and the llvaacoek 
togBthar te ha^ axpadlta laplaaaAt^tlcm of 
a appaieut that Ihe policy ueda nvlitBg, 



■port legislation auch aa B.K. 6725 al this 
chance to wtk. It Che policy ia promt 
ve VDuld ba plaaaad to Teapond Co u^ 

e Alght have. 






D,B,i..ab,Google 



' National Wildlife Federation 



> BoBorabla B. 0* li 

alman, Subccnmlttac --. 

InveitilgatloTiB , Oversight, ind Maaaioh 

E. Booae of nepresentatlTe* 



n viOi 4 e nillle 



As yon knoi, tb* ptoMan of llTaatock loaaai to pradators 

has bean vlth UB foe ■ vaiy long tia*. It ia a problem vlth 

have bsec <]one. Unfortunately, there SKA atlll feu clear-cut 
ansvacs to Borne of the problema asaoclatad with ttia llvaatock 
Induatry and pradatlon. 



to pradatora 
pt of pro- 
e loaaes. 



of caiaful ravtmi and intanalva atudy, tha 
ior laauad a >a>o on Hovasbar }, 1979, to 
i tha Anlaal Danaga Control (KDC) FTograai. 
tary baa propoaad a vary c '- 



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OtJiar tlian what tha iU)C ptogtim la already doing ondar tha 
goldance of fiecretsry Tuidrua, the only thing* H,R. G72S mold 
raqulrs acai U) tha Batabllahmant of an ad hoc ovacaigbt 
conBltteei C) the cooperation of tbe Eecretary of Ageionltnrai 

(3) reiearch and operational use of compound 1080 (iriiloh la 
presently illectal for operational predator control uaall and 

(4) emphaaii on the uae of 'preventive control taohnlqnaa' 
to reduce predator populatlone. 

Mhlla wa faal that the first two abova Mould nalthar 
significantly add to nor detract froa tha praaant problaB, 
we vigorously oppose continued wor>: with eo^o u nd lOSO and 
any attenpt to reduce livestock dapradatlona by a ganaral 
lowering of coyote populatlona. Wa tharafora oppoaa tha 

pasaag* of B.R. 6725. 

ni* coyota la a highly auocaaafnl and adaptable animal. 
Mhere other anioals have peclahad, it la flourishing. Bow- 
ever, coyote population levelfl are reflective of their habitat 
and food supply (nmlnly rodents and rabbits} and generally 
have nothing to do with the preSanca of livestock Areas 
with high coyote densities have high rodent populations and 
tha coyotes ore functldinlng in «n important predatory role. 
Because coyotes play such a vital role In the ecosystem. It 
would be a great ndstaks to eradicate them. Only massive 
poisoning prograaa could lower coyote levels to the point of 
halting all livestock depredations. Such an undertaking would 
be disastrous to the other «lenenta of the environment, and 
ootlld not possibly be cost-effective 

Compound IQSO Is so hazardous a pradioide that It desarves 
■pccial mention This chemical was developed in 1!>44 for 
use In controlling coyotes, however it is toxic to other animala 
In vsrylng degrees. It is particularly toxic to neinbers of 
the dog family, one pound of it being enough to kill approxi- 
mately B quarter of a million coyotes. However, since It is 
also toxic to other animals, many thousands of non-target 
anlnals have died from 1080 poisoning. Exact loss figures 
are imposslbla to obtain because of 1080 'a mode of aotion. 
The chaulcal takes from one to twenty-four liours to aot, 
than the animal goes through massive convulsions until It 
diss. Because the animal has liad sufficient time to wander 
away from the bait station, it Is impossible to recover many 
of the carcasses tha result Is that animal damage agents 
•re unable to properly aaaaaa the success of the control 
effort, and many wild acavengera and predators Whlcb feed 
on the bait becoaa son-target Tlotlma of polaonlng. Evan It 



D,g,tze:Jb.GOOg[e 



the bait ■tation* h*d th* >liiiw» Mwunt of aotfpovai IDSO 
raqulrad to •ffacttvsly hill a corofca, thara would ba Bora 
than anough to kill a kit fox, a gray fox, or even tha 
aodangered black-footad ferrat. Bobcats, badgera, and 
golden eagle* could easily die from eating joat two of the 
Hinlmum aingls lethal coyote doaea. nie national Hildlifa 
Federation doea not oppoae further ceaearch aiaed at 
developing a pradiclde that ia apeciflc to ooyotea. But 
ve feel it ia tine to abandon lOBO. It ia not a panaoaa foi 
the liveatock indnatry'a predator probleM*. 

nie ultiaate solntlona to tha predator problw will be 
proper huabandry practicea, coobineA With effeotlve non- 
lethal and offondar-apaciflc lethal teobnlquaa. We urge 
thia anbcoamittea to reject H.R, G735, and allow Secretary 
Andrua' program to oontinva. 



SiAcarely, y 

^^Sm^ — 

BxacBtiva vice Frealdent 



D,g,tze:Jb.GOOg[e 



Kuolutloa Ho. 1 

mmuiBMEHT or premtors 

HBEREAS, ttia national Wildlifa radacatlon lacogntia* Uw Intrleat* 
relstlonihlpa batwvan apaclaa of wildlifa and tbair anvirooMPtai and 

tSEDEAS, It ia raco^nlied chat prodacora aecva a valuabla tniNtioa 
In tha total acologioal balanoa batwaan apaciaa of wildlifa and tbalr 
hobitatai and 

KHEREAS, luny natural conflicta occuE batwaan wild pradator aalBals, 
ga»a apeciea and domeattc animala. Including livaatocki and 

KHEREhS, In spacific Inacancaa it la deairabla to nauga thoaa 
individual anluli which conilatantly pray upon donaatlo llvaatock and 
which nay b* doing excsaaive damaga to gana apeciaai 

HOW. THBBEroRE, BE IT RESOLVED that tha National Hlldtlta rodaratloa. 
In annual convention aaaanbled March 4, 1971, in Portland, Orag., bacabr 
contlnuaa iti oppoaltlon to tha wida ipread application of dangarous 
chenlcala and davicea and expresiaa tha opinion that aiiy contcol 0< apacltla 
pradatoTB ahould b« performed by trained goverrunental prof aailonala ^ elthar 
Federal or State, utlliiing niethods determined by auitabla raaaartA and 
baiad upon proved need for lunagement in each instance, when dangaroua 
chsnlcala or devicei are involved because of the potential haiarda which 
th^ praaent to hunana, domestic liveetoclt, and to beneficial fonu of 
wildlifai and 

BE IT FURTHER RESOLVED that this organltatlon axpcasaas its strong 
conviction that, to be effoctlva with the least posalble dasug* to bana- 
ficial creatures adequate funds moat be appropriated to allow a^loyswnt 
of suitable numbers of properly trained technicians. 



D,g,tze:Jb.GOOg[e 



Y OP / 

an. DEDE ARMElJTftOUT 

REGIOMU, REPRESENTATIVE, NATICTWL AUDUBON SOCIETY 

BEFORE THE 

SENATE eNVtHONMENT AMD PUBLIC HORKS CCMIITTEE 

2S ^rll 19S0 

Kf n*M i* Dr. Dada Anentnut. I ■■ tho Haticmal Audubon SoeiMjr'* 
TSprasentBtlvs for its Southmit Raglim. I have a Ph.D. in ph]rsiolafickl 
Bcology titm Texas Tech Italvenlty. I ^ipreciate the c^portimity to 
present to 70U and jrour cnalttee the Society's views ifith respect to 
recently annomced policy changas for the Aniul Daaage Contiol Divislm 
of the IS Fish and Hildlifs Service. The Kational Audubon Society is One 
of the natirai's oldest and lariest conservation organliatlons with s 
■eobership in excess of 400,000. Our Interest in healthy ecosystMS 
extends to predators, which are an integral part of Bost ecosysteax. 

Me have been active in field and liteiature research Involvini 
predator-prey Telationships for soa tlae. The six national Audubon Society 
ivgional offices which sarva the western Iftilted State* have all bean 
involved in predator- control issues for aany yean. Bob Turner, an 
Audubon staff aenber served with represent stives of other public interest 
organizations, various fovemaant agencies and the livestock industry on 
Seeretaiy Andrus's 13-B<tiib«r adTlsory panel on predator control. Recently, 
in Eaat Texas, I have personally participated in three days of field 
testing on toxic collars containing sodliai aonofluoioacetate, better known 
as Compound 1080. 

Although mch heat has been generated by Secretary Andrus's announcewnt 
of new directions in Anlaal Dsaage Control research, we are soaewhat at 
odds to understand why the Ilvestoc): industry has reacted so vehenently. 
It appears that, such to the dissty of conservation groups, virtually no 
lethal controls have been taken away. Aerial hunting is still in effect. 
the H-44 prograa is still In effect, trapping and shooting will continue to 



D,g,tze:Jb.GOOg[e 



ba taployad. Tlw S»ci«tu]r ha* elialnMod ifm hl^ljr contravanlml ntd 
nlBtivalr iuifBlflcant lathal tadmiqu*: that of dannlnf on pobllc ' 
landa. Prlvata landnman can contlnoa tha dnrnlnf on thalr oon praparty. 
1h* policy pnMl*ai naa aafihuls on axtaiuion larvlcas and Inciauad 
iMMrch in non-lathal contiols. Sacratujr Andnii ha* pisalsad that aoa- 
IMhal coDtTOls will hava to pnvb affMtiva baftin thajr laptaca tha latkal 
nathoda now Mployad. Frankljr, it doaa not tpptti that tha llvaitock 
InduatT? has lost ai^thlnf. In addition, succasshil resaanh diractod at 
Daa-letbal i^naehai aill enjcqr ■ mnA broadsr basa of siqtport, nltlaataly . 
pnwidtng .nnchaTs with conttoHiditeh afo affactivo for thaa and acciptabla 
to BiivinnMntalists and tha ganeni ptOillc. The National Audubon Soeiatr 
sivports SacMtaiy Andiut's prddator pAlicy^ith Taspact~to the'tteM Motlorfd 

For Mny years m hava UT(od rasaareh and davalopaant of non-lathal tools 
for pTsdator contiot. At Um s*m tUw h hava racognliad that tathal controls 
■ara a political reality. Me have uT|ad that lethal contials, irfian 
aifloyad, ba spmiias-spacific, and in so far as paisibl*. directad at tb* 
oftiodinf individual predator. A tool and technique currantly undar 
active eitpariaentatlon by ADC shows wich proaiss in the direction of 
individually taTgeted lethal contiol. I refer to the toxic collar. Tha 
toxic collar is a defies contstnins a poison in liquid foia. Hie device 
is placed around the throat of a shaap or loat. A predator atte^itlng to 
bite the throat of an aftlaal so equipped wilt pierce the collar and cansa 
tha release of poison into its om aouth. Iheoreticall]', tha offendlnf 
predator and nona other is poisoned. Ihe national Audubon Society s>9port« 
tha concept of the toxic collar and views It as an effective lethal control 
that wa can live with until and unless ncm-lethsl techniques prove to ba 
as effective. 



D,g,tze:Jb.GOOg[e 



One poison empiayei in raioarch on tho toxic collar has b«en 
sodiua WHwfluoroacetate, also knom as Compound 108O. This substance ns 
bannod by the Envlronamtal Protection Agency stae eight years ago, 
priaarlly bacauia of its persistence and its high toxicity. At the tlae 
it Has bannad, Coapound lOSO Hss widely used In hl^ concentTations at 
relatively non-seleetlve bait atatims throughout the iwst. Field 
observations In the vicinity of 1080 bait stations revealed that killing 
lias indeed non-selactive. In addition, large concentrations of this 
highly toxic, cheaically stable co^iound, scattered throughout westeiB 
lands led to fears of mter contani nation. Wide distribution of ■ colorle**, 
odorless, tasteless, highly toxic, highly stable poison with no anteilota is 
Indeed a situation to cause fear in a rational person. 

Early results of Ilaited secondary poisoning experiaants, using 
collar-killed coyote carcasses as food for aagples, have given proaising 
results. So far, there does not appear to hsv* been a short tera secondary 
hazard to Bagpies xhich mre fed on collar-killed coyotes. Very lIiiitMl, 
similar experlaents with eagles and vultures also fail to deaonstTate 
detectable short-teia secondary hazards. Individuals of the livestock 
Industry seized upon thsss prellalnary and very incM^lete results, 
erroneously concluding that Coquund 1080 itself was safe and free tnm 
haiards of secondary poisoning. The livestock industry has begun to 
claaor for registration of lOSO, suggesting now that all the fears of 
the '70s were unfounded, lliey failed to understand, and ADC failed to nphasi 
to then, that Co^raund lOBD as the ADC was using it in toxic collars 
presented a vary different situation titm that of the pre-ban bait 
stations. It Is precisely the differences between the toxic collar and 
the bait stations which has generated tnaendous confusion and 
aisunderstandlng within the livestock InAistry and the envlnmaei 



D,g,tze:Jb.GOOg[e 



M ladantandlai of tha dlffaraicM banMii tffact* of lOU In eollam 
vmin talt itatiBU 1> ouclal to tht* cswdttaa's ability to Bika 
Intalliient avaluatloni of tha isina. 

Pnlialaaiy raaulta sugtait tbat CaifiKBi lOU, at tha doaagai UMi 
In tha racant toxic collar fiald tasta, could kill an offandlng cojrota 
althout laavini ■ tnaandoui rasldua of poiaoD in tha onviranaant and 
■Ithout ■ahing tha polioD raadll)t avallabla to othar than tha tufat 
Individual. Thla would b* espaciall)r tnia, if paituzoi war* checkad 
dailjr and bnken collan and contsalniteil carcsaiai vara naovad. 
lOtO placad in bait stations, In-ttaa doaaies naadad fOr an affactlva bait 
ttatloD, cannot offar tha itma anvita w is n taJ sacultjr. lb undaatmd 
Hh)r tbl* is tiua, one Bust imdarstand loasthini of the my Ccapoond 1010 

In its oiittnal fora, ftn could »ty that Co^nund lOBO It latent. 
It mpptm that an anDiaa inside the cells of the victia convarta >«■• of 
the ce^wuDd to an actively lethal fan: fluoracitrate. Dm flooradtnte 
lnta«£eres with tha cell's ability to pnicaas mnar- and thus the coll* 
quickly die. Nhen call* in vital orgens die, the aniaal dies. If an 
aniaal Tecelvel just a lethal dose. It is believed that all thaXoa^ouid 
1080 will be converted to other faras including the active lethal fon 
that kills the aniaal. No residual Ca^Knmd 1080 would be left in the 
carcass to posa secondary poisonlni hazards. The actively lethal derivative 
of 1D80. fluoiocltTBte, while deadly In the cells of the vlctla, is thmfht 
to be haisless to enother aniaal feadln( on the carcass, because it li 
believed to be detoxified before reaching the cellular level Of the 
secood aniaal - 

If an aniaal receives aultiple lethal doses, its cells will still 
begin to convert the Co^ound IDSD to fluorocitrate and other derivative*. 



D,g,tze:Jb.GOOg[e 



but the anlBil will die befbre all of the Coq^ound lOSO is converted. 
Consequently, stmt Co^oimd 1080 will rcaain In the carcHS, subjecting 
scavengers to lecondar)' poisoning hazards. The greater the dose of 
1080, In excess of a lethal dose, the sore 1080 will reaain, and the 
greater the secondary poisoning hazard. 

Obviously, the closer one ccaMS to achieving an exact lethal dose, 
the greater the chances of ainiBliing risks of secondary poisoning. Toxic 
collars. can, to sodw extent, control the ueount of lOSO the target anl>al 
Ingests. Bait stations, in irfildi pieces of aeat are laced with large 
doses of lOSO, offer high risks of secondary poisoning, axposa the 
envinniBent tA'.sustalned presence of large doses of 1080, and are 
non-selective with respect to the offending aniaal. The persistence and 
toxicity of Coifiound IDSO during sustained exposure In bait stations have 
never been sufficiently studied. 

Co^)ound 1080 shows soae proaise of effectiveness and' seltetivity ' 
when used in a toxic collar program in response to specific predatlon. 
Co^)oiind 1080, in aasslve doses at bait stations does not show'pnxiise 
of envlronaental safeguards, or selectivity, needed in handling such a toxic 
and stable coiqMund. 

Even In a toxic collar prograa, there are Mny; though not endless, 
liqiortsnt unanswered questions about Coiq>ound 1080. Hich further research 
is needed in critical areas. Som deficiencies are noted below: 

1. Secondary poisoning studies are in the MSt preliainkry 
stage* with few species sudled so far. tlore species 
which are likely to encounter and sai^le 6oyote carcasses 
should be studied. Statistical **]^lss are needed. 

2. No long-tera sublethal effects of 1080 have ever been 
investigated. Reproductive Interference has' been docmiented 
in raptors exposed to other organic pesticides, litis needs 
to be investigated. 



D,g,tze:Jb.GOOg[e 



3. Search for an effective antidote need* to continue. 

4. Coapound lOSO i* Ketaboliied to other co^Kumdi, not 
all of lAIch have been Identified. All the Mtabolites 
need to be Identified and their role in potential secondary 
poisoning e^lored. 



Toxic effects. If ai^, of the lethal Batabollte 
fluorocitrate should be studied. It is believed t 
be harBlasa when ingested, but as yet there are no 
experiaental data to siqtport that i^iasslon. 



8. Persistence of 1080 mad toxicity in carcassas and aoil 



In departure firas Secretary tadrus's announced policy, the Hattonal 
AudubMi Society vould urge continued research on Co^raund 1080 to answer - 
the above quest ion*, inlfe are not ttrtii to seek the truth and ho tuppott 
research to that end, but ve do not siqiport a diverse, unstructured 
allocation to various states of a progran that at this point needs closa . 
coordination and focus. He fear that states Hill iqileaent preaatnre, 
Midespresd "field tests" in the nane of research without resolution of 
the significant questions and without proper envircwiBeatal avfagoards. 

Ihe randiing industry 'should recognise the possibility that, after ■ 
thorouf^ research, 1080 say be t«und unacceptable. Public objection to 
th« substance, co«9led with the dangers of such a pawei fi il toslB, and '- 

the potentials eSr its abusa aay cosine to prove Secretary Andrus 
correct in tJie end. Co^otoid 1080, enren if exonerated in toxic eollar 
iVPlications Bay be too controversial to ovar win broad public * 



D,g,tze:Jb.GOOg[e 



In tiM preceedlng *j c u ^ m tB ham been rasponalv* to Sacralary 
Andnia'a aimouiiCAd predator coatrol policy. L«C ■• take thla opporcontCy 
to place tbe Maclonal AuduboD Socletr'a T«apona*> to this llsLcad iaaua In 
a bioadec perspective. 

Today Uioae intereated In wildlifa and haalchy acoayst^ say vlaw with 
bIbtb the ataggerlng loBses that our natucal rennrable resoureaa have aufCaced 
eapeclally tAen they have been perceived In conflict with real oc projeotad 

Babltat loss seeas the undisputed laadec aanis tbe canaaa of alldlUa 
loss and eeosystea disruption. 



real estate davelof ent anid highway construction. 

Alaoat half of this aoiiual loea of agricultural land 1^ offset 
by bringing other lands Into oarginal production oftaa through 
draining of vetlands or converslan of other bl^ wildlife areas. 

2} Eroalon costa us about 5 billion tons of topsOil per year 

depleting or degrading terreati^l habitat wbUe also degrading 
rlparlaa, n»<i- and sstuarloe systeas. 



It appears that we ac« losing plants and anl—ls at the rata of om 
■peclss per week, worldirlde. 

In the VBBt BBjorlty of casaa vorldwide. when wildlife has case In 
conflict with huaan desires wildlifa has lost. 

Significant conaidaratlon of vlldllte resources sod significant pro- 
tection of healthy eeosystana aul their coaponsnts h«ve b««n recant In dM 
Dnltsd States. 

Spades rlctanasa, hebltat dlveralty, h^th, ao^allj-fimeelonliis 
acosyatcBs are all essential to anrrlwsl. MhaChar ladtvldBals ncagBlM 
this or not, la^acta on conpoMOts of the ecoeyst^ ratnn U tnndh nU 



D,g,tze:Jb.GOOg[e 



at ua. Today tba accoolatad thraatB to oat acoayataa* era waniMantal. 
Bach IndtvUual Chcaac May b« ratlonallaad ma; by aoaa apodal Intaroat 
gnup oho would find It azpodtaat and aeoooaleally prof olabla to Icooro 
•orlTODBantal coocerw. Ha Tocogniia tbo na^ foe anlMal d^Mg* eootrol 
In lagltlaata daprodatlon eaaoa, and do not hara faaza for tba livadtat* 
daataa of tha coyote. Bat «• do faac tba Dltlaato l^Ucatlona of an 
■niaal daaaga control nlnd-aot vfalcli la. ao |Oal--«claiitad aa to Igoora 
tba natural and appropriate role of pradatora, and is ao indlacrijdnata 
In Mirliniliilniij aa to ultlBatel; ebreaten aany coa^onanta of tba aco- 



D,B,i..ab,Google 



Kr. Chairman i 

My oame la W. Bert DennlB, For years I have been Uie 
ovfner-op orator of a cattle and sheep ranch near Gall, the 
county seat of Borden County, IFaxaa. I am President of the 
50 year old Texas Animal Danaee Control AsBOciation, Inc. In 
addition, I aa a co-signer for the Association in the three 
party master project agreeinent between the D. S. ?ish & Wild- 
life Service (D. S.S.I.), the Texas Agricultural Extension Ser- 
vice and our Association, As one of the official functions, 
I am the custodian of the Texas Cooperative Trapping Fund 
vrhich la conposed of money contributed by County Coimiis si oners 
Courts, livestock protective associations and individuals as 
their share of the cost of predator control on properties 
which they own or lease. Until last year th.ess funds equalled 
those provided by federal appropriation. The State of Texas 
through its Rodent & Predatory Animal Control Service provide 
the remainder. 

Membership in the Asaoclatlon is almost evenly divided 
between cattlemen and sheep and goat raisers. Poultry and hog 
producers are becoming an essential part of this organization. 
They reside in all parts of Texas ranging from the Rio Grande 
Valley to the Panhandle, and from the Trans Pecos to deep Bast 
Texas. We do not have a large membership but the quality and 
integrity of the members is unquestionable. They Imow the 
problems created by cougars, coyotes, bobcats, foxes, ■ininirH 
and raccoons most of which affect the managenent of wildlife. 



dbvGoogle 



livestock, poultry and cantrol of wild ""*"■''' ^ome dlaasaes. 

It is on the basis of 117 knowladge aad Bxp«ri«iio« and 
tliat of the memberBhip that I Teapactfully request jour atten- 
tion to my testiiDony in this iiq^ortant matter. Attention to 
this program by the Congress is essential. The U. S. Depart- 
ment of the Interior which stqiemBes the Animal Dsmage Control 
Frogrsffl through the D. 3, ?ish & Vflldlife Service hss Inten- 
tionally failed to implement the Act of March 2, 1S31. 

This lack of adherenea to the nrineiplas of tbat law 
was due to directives issued by forr.er Secretary of the Interior 
Stewart L, Udall in the early 1960'8. Prom that time to the 
present the intent was to reduce the program, especially the 
predator phase, to the extent that it wonld naturally suocumb 
through neglect. The currant Administration eeeme Intent on 
the aame purpose. I am convinced, as are our SlxectorB, that 
this plan has an excellent chance of success unless the Con- 
gress now In session takes remedial ac' l.on. 

I would like to place in the record some of the events 
and actions which have brought the program to its present con- 
dition, and I might add, a condition that has caused a serious 
decline In the asprlt-de-corps of the most important element in 
the organisation — the field operators who do the actual work. 

The program has been under continual official and un- 
official review. The Act of March 2, 1931 was passed by 
Congress with the support of the Hammal Society, Leaders of 
that organization admitted that they loiew little of the program. 



D,g,tze:Jb.GOOg[e 



Ihey bad been told by the ao-caUed Bcientists ot the day that 
predator and rodent control was insetting the "Balance of 
Nature". Thsy called upon the Division of Predator and Rodent 
Control of the 0. S. Bureau of Biological Survey (now U. S. 
Pleh and Wildlife Service) for an explanation of the program. 
As a result, not only did they give verbal aupport to the pro- 
gram but they also recommended a million dollar a year appro- 
priation for ten years. The results of the investigation were 
largely due to the integrity and objectivity of both the 
Hammal society and the Bureau representatives. At that time 
members of the Bureau, including the Director, vere thoroughly 
familiar with all aspects of their total program and knew the 
value and the relationship of each. They paid particular atten- 
tion to the word and the Intent of Congressional legislation 
and eagerly accepted it as their mandate. It would bs quite 
refreshing if such a situation were possible today. 

Over the years predator and rodent control personnel at 
every level were frequently subjected to adverse and damaging 
criticism by "Balance of Nature" proponents. Many of these 
had no Interest In hearing the facts. They had little firm 
siQiport until publication of the Leopold Report In 1964. 

This was the Advisory Committes on Wildlife Management 
appointed by Interior Secretary Stewart L. Odall. During ths 
period of Its investigation, committee members had little con- 
tact with Service personnel In the predator and rodent oontrol 



D,g,tze:Jb.GOOg[e 



field. Hot did they visit with rancbors except for those 
who were known to have no need for control aaaistance. In 
essence, comnlttee members wrote their report on the basis 
of pre-concelved notions. 

The Conmittee declared that the work conducted was 
far in excess of the needs which supported the claims of the 
"Balance of Hature" enthusiasts. However, they made one un- 
expected statement: Compound lOSO was the most selective and 
humane method of control. 

On the basis of the statement on excess control, for 
several years bills were introduced into the Congress that 
would have reduced the entire staff to six persons in the 
Onited States with a budget of 1105,000. 

To further follow the direction of the Leopold Report, 
the U. S. Fish & '.Wildlife Service changed the name of the 
program to Division of Wildlife Services. This diluted the 
efforts of the field staff in what was now to be known as 
Animal Damage Control by the addition of duties in pesticide 
surveillance and wildlife enhancement. There was no increase 
in staff. 

Seven years later, in 1971, a new investigative team 
was appointed by Secretary Rogers C. B, Morton. This, the 
Cain Committee, differed in Its recommendations. I^lilce the 
Leopold Committee, this one declaj-ed toxicants to be invalid 
because they were inhumajie and nan selective. Leopold classi- 
fied traps as being inhumane, Cain recommended that landowners 
be trained in the use of this age-old tool. 



D,g,tze:Jb.GOOg[e 



The result of the Cain Report was the delstioa by Sxe- 
cutlve Order 1164? of toxicants (Conpound 1080, strychnlnef 
BodluiD cyanide) from use on federal lands and in federal pro- 
grams. Private landowners could not conduct their own work 
because the Bnvtronmental Protection Agencj placed a ban on 
the Interstate shipment of these chemicals for use as pre- 
dacides. Those who possessed any of these materials were 
directed to send their supply to E.F.A, Regional Offices. 

It would appear that the Cain Committee, the Sierra Club 
and the Defenders of rflldllfe made decisions relating to poi- 
sons at about the same time that the Cain Committee was appointed 
by the Council on Environmental Quality and U.S. S.I. . Evi- 
dence of this is a suit filed by the tuo groups against U. S.D.I. 
regarding the damaging effects of poison used as a predaclde. 
The U.S. D.I. response vaa to the effect that: "Let's wait 
and see what the Cain Report has to say and then we will put 
an end to poisons." Thle, as It turns out, was the secret 
agreement that we learned about at a later date and could do 
nothing about. Hearings were promised but not held. D. S.D.I, 
had made up its mind, and even with a change in political leaders 
still refuses to consider Compound 1080 or strychnine. 

Later, at the beheet of several rancher organizations, 
several extensive field tests were permitted by the E.F.A. 
which finally allo^ved registration of the field use of sodium 
cyanide in the M-44, along with 26 restrictions. 

The attitude of this state of affaire by the Department 



D,g,tze:Jb.GOOg[e 



of Interior Is wall repraaantad by Its rawttlon to a raqnast 
for training of ranchars in tb« iiso of tho M-44< S<P>i* had 

granted the Texas Separtmant of Agriculture a permit to t«st 
the efficacy and safet^r of the M-44 In tha hands of ranohars. 
E.F.A. aalted Interior for aaaistanca in rancher training. 
Interior solicitors decided that Sxecutivs Order 11643 did not 
permit sucb assistance. H.S.D.A. solicitara decided that aueh 
assistance v;as veil within the frame-work and the intent of 
E.O. 11S4?. This resulted in the requirement of £xtenaion 
Uildlife Biologists that they leam the techniques as well as 
possible and proceed to train ranchers and farmsra vho requested 
such training. 

I would nice to emphasize that all this tijns the federal 
and state employees in the program with which I am associated 
were barred from assisting in this important pro^vn, Howerert 
since there was no one from whom extension personnel could 
gather the necessary information, two top level federal auper- 
Tisors took time off the job to assist in the dsTelaioMnt of 
this Important training program. (This attitude Is far differ* 
ent trom that which is espoused by U. S.D.I, today.) 

Assistant Secretary for Fish, 'Wildlife and Parka, 
Nathaniel P. Reed, was strongly opposed to the entire progrwi. 
He did not look upon native, resident wildlife as a federal 
responsibility. He has been quoted as a^ing that he did not 
see the coyote as a federal animal. One of his plans to gst 
out of the business was his offer of a maximum of a 1300,000 
grant-in-aid to any stats that would taks over the program. 



D,g,tze:Jb.GOOg[e 



The states did not accept l3«cause of tbe federal restrictions 
that would be a part of the graat-ln-ald packa^^e. 

The continued outcry over the arbitrary deletion of 
poisons without any hearings resulted in a modest Increase in 
funds to further the use of mechanical methoda. Program leaders 
were required to show ranchers that tliey could receive protec- 
tion without the use of poison. The magnitude of the problen 
In Texaa was such that the addition of a few dollars was of 
little value. Usually the employment of additional hunters 
will help solve strictly local problems for a short time. 
Hm-rever. these federal fxmds were of no value for this purpose 
because the personnel celling did not permit the Animal Damage 
Control program any new positions. 

The alternate was to institute a modest program of 
aerial hunting in Texas. Unlike other states the areas of 
critical need could not be safely hunted with fixed wing craft 
because of the rough terrain. Consequently, helicopters were 
used at much greater expense. But the federal allottnent was 
so small that we had to use funds of the Texaa Cooperative 
Trapping Fund which I mentioned earlier In this testimony. 
This program was expanded by an allottment from the U. S. De- 
partment of Agriculture. Interior would not asaiat with any 
addition. 

The purpose of aerial hunting was to find coyotes that 
had evaded the best efforts of the resident predatory "'<'"i 
hunter and even that of expert trouble shooters. In addition. 



D,g,tze:Jb.GOOg[e 



It was nocessaxy to work In ontolde areaa In an attest to 
contain coyote Ingress Ccom unprotectad araaa* 

I would lUca to ralate my own parsonal experience with 
aerial hunting. In 1946, when huntera were permitted to uaa 
poison as well as mechanical tools, I soon learned that If my 
struggle to develop a ranching enterpriae were to be succaaafuli 
I would have to do sonethlng to sx^plenent what the huntaro 
were doing. I was forced to go to the expanaa of purchasl^ 
and learning to pilot a plane with which to provide the extra 
effort needed. I wiah to repeat: without aerial hunting I 
could not have survived In the ranching business. However, 
it was, and Is only one of the needed tools. Itotll 1972, trapa, 
snares, H-44's, strychnine and Compound 1080 were all In uae 
on my property and that of ay neighbors. 

It would seem that with this array of methods the coyote 
population would soon be reduced but this proved to be wishful 
thinking. Although more predators were accounted for, popu- 
lations still increased. This was forecast by supervlaory 
personnel as a result of which they continually besieged the 
Denver Wildlife Research Center personnel for additional toola 
and cooperated with that group in every way possible in the 
field testing of the various candidate processes. 

The ban on Compound 1060 was most serious over that part 
of the state which lies west of a line from Corpus Chrlsti to 
San Antonio to Ft. Uorth, In some counties, especially thoaa 
m the Rio Grande Plain and the Rio Grande Tallay, there was 



D,g,tze:Jb.GOOg[e 



no usable substltnte. County CoomilBa loners vrere tma'blo to 
provide their share of funds for more than one hunter, whereas 
at least four were needed in each county to replace the loss 
of Compound 1060. In the aheep and goat raising area those 
who dared to allow at least a lOK loss remained in business; 
others were forced to aeelc an alternate sotiroe of Incone. 

The search for an alternate enterprise In some parts of 
Texas, especially In the Hill Country of the Edwards Plateau* 
is a useless exercise In frustration. The terrain and the 
vegetation is intimately related to sheep and goat production. 
Although cattle are raised this is not a profitable venture on 
the relatively small ranches which are the rule in this area. 

Poisons are uniquely adapted for use in protecting cattle 
because they can be quickly applied, removed on schedule and 
v;lll cause an approximate reduction of coyotes in the neighbor- 
hood of 3C^, all with little Interference with ceuLving periods 
and little effect on the future of coyotes in the area. 

A factor frequently overlooked Is the value of coyote 
reduction for the protection of game, especially deer. These 
animals drop their fawns at about the same time as coyotes are 
still feeding solid food to their pups at the den. It has bean 
scientifically demonstrated that coyotes are a major source of 
fawn mortality. In much of Texas, the sale of deer leases to 
sportsmen is an important source of income to the rancher in 
tine of the severe, recurring droughts. During the 1950 to 
1937 drought, deer lease aales were the sole source of income 



D,g,tze:Jb.GOOg[e 



to Sotttli lex&s TBnchers. Livestock could not exist under 
these conditioDB. Coyotes and d«ar do rsasonably well. 

1^ frequent reference to Compound 1080 should not ^e 
ccnatrued as being the chemical of greatest Importanoe, Hot 
do I intend to convey the impreaslon t)iat its return to field 
use Mould solve all our coyote problems. The facta are that 
along with the ban on this chemical, strychnine was also pro- 
hibited. This, at once, caused a serious problem in the pro- 
tection of human and domestic animal health. In the presence 
of an outbreak of rabies, all wild carnivores may become car- 
riers prior to their own death as a result of which humans, 
pets and livestock are subject to infection by this dread 
disease. 

When rabies is confirmed by laboratory, swift action 
is necessary. It is necessary to reduce the number of other 
animals that may be bitten and so increase the number of car- 
riers. Strychnine in a meat or tallow bait placed on the ground 
and covered from view by birds is an effective solution. Con- 
pound loeo is not suitable for this purpose because the dosage 
would have to be too high to affect animals other than the 
canines. Such baits will attract and kill, those carnivores 
whose range lies within the area of bait placement. Ro others 
are affected. 

In our experience, when notice of on outbreak of rabies 
is diagnosed by health depairtment laboratories it ia possibls 
to treat the area at the rate of 230 square miles with eight 



D,g,tze:Jb.GOOg[e 



men In ten botirs. The only requlTements are that baits be 
prepared and stored for euch an emergency; that deaignated 
personnel are trained in the details of proper bait site 
selection and that the rancher be available to conduct the 
specialist over the ranch. 

The Environmental Protection Agency is fully sMare of 
the procedure and, at the request of the Texas Department of 
Health did permit the application of strychnine treated baits 
for this purpose on at least three occasions. As in the caae 
of the M-44 training request mentioned earlier, personnel of the 
Animal Damage Control program in Texas were prohibited from 
participation in any form. Aa a consequence, certain officials 
again provided the training which the Health Department needed 
without delay. 

The refusal by U,, S.D.I, to participate is only one 
more exaiQ)le of Its callous attitude towards the needs of 
people. It reflects refusal to adhere to the letter and the 
intent of Congress when it passed the Act of March 2, 1931. 

The situation which existed prior to the President's 
Executive Order is not fully understood by many people. Evan 
vrhen all materials new banned were In full use, we were aua- 
talning serious losses. It was obvious at that time that the 
local program was a failure. In an attempt to alleviate the 
situation since we had no response from D.S.D.I., the Texas 
Sheep and Goat Raisers sponsored a referendum aa permitted by 
law in an attempt to secure- sufficient funds to supplement the 
Vi-ork that was already being done. 



D,g,tze:Jb.GOOg[e 



One of the problema we facad was tbat ws were not fully 
aware of the policy restrictions placed upon the state program 
by II. S.D.I. These restrictions are contained in Han and Wild- 
life the Animal Damage Control FoXlcy of 1965. As is usual, 
the restrictions In this policy were not as serioiia as those 
of a supplementary nature that were imposed by lesser offlciale 
of the U. S. Pish and Wildlife Service. 

In the development of policies at any level, attention 
was P^d to the objections raised by the groups which claim to 
be environmentally oriented. The fact that they know littla 
of the environment of which we are spea]cing and care less, 
what they say or that which they demand la given close attention 
by U. S.S.I. The farm and ranch organizations and their spokes- 
men are given no attention. The attention paid to testinony 
from our Association during the hearings which led to the 
current U.S.D. I. policy Is definite evidence of ray contention. 

Although project leaders are provided with the frame- 
work of a work plan and are required to nake plans for their 
state (they labor under the restriction that permits reaction 
to problems but no direct action until after the fact. Ths 
basic Idea is that attention will be given only when and where 
there is a demonstrated need. Project leaders have been in- 
structed not to allow their assistants to accept the word of 
the rancher concerning losses. If the policy were followed 
verbatim In the field we would have no assistance unless a 
person accepted as being qualified by the hierarchy would 



D,g,tze:Jb.GOOg[e 



examine the remains and declare that a predator was the cause 
of death. 

We do not need protection for dead animals, we need to 
protect the living. 

When a cougar appears in a pasture it is a well-known 
fact that it will soon make a kill for food or several kills 
for sport. Although it prefers doer it will make a kill pf 
whatever animal is easiest to capture at that moment. At this 
stage of the game hunters are not permitted to stop ingress 
of lions. They must first wait for evidence of a kill. They 
never know the extent of killing prior to finding this evidence. 

Ones evidence is found they must send word to the super- 
visor. In the remote parts of Texas where lions are numerous, 
post offices ftre rare and telephones are non-eslstent. But 
he is not permitted to act without permission. Consequently, 
damage may be severe and the lion may have moved on before the 
hunter con place his traps. Prevention ia prohibited but only 
prevention can protect livestock in such cases. 

The Defenders of Wildlife had complained that lions were 
scarce and so the prohibition was prepared and sent to the field. 
I can assure you that lions are not scarce in the habitats they 
prefer. Parks and '.Wildlife Biologists can attest to this, 

Vi'lld dogs can be a problem in some parts of the state. 
Control of these truly feral animals miist be held in abeyance 
until the hunter makes a report to the supervisor. 



D,g,tze:Jb.GOOg[e 



It le then tranamittad to the atata offlcs along wltb suit- 
able documentatloa and then on to the Area Offloa, the Staff 
Speclallet in the Reglon&l Office, the AeelBtant Regional Supar- 
TlsoT and finally the Regional Director who leauea hla deolalon 
In ifTltlng. B7 the tin* it reachea the hunter, much daaage 
haa been done unlesa the hunter and the rancher take dlrsct 
action then and there In violation of the directive. 

The recent decision by Secretary of Interior Ceoil D, 
Andrus Includes emphasis on an extension education proipMn 
In which ranchers and farmers are to be taught how to conduct 
their ovm control operation. (If such a pro-am would have 
been effective In my area I certainly would not be spending 
3450 per month to the Pund.) In order to conduct a training 
session the program must be sold to the people. But to n.S.Dd* 
this Is solicitation and is not to be condoned. This was «w 
of the severe criticisms in the Leopold Report. Althou^ it 
referred to operations some of the latter iay si^ervisors in- 
clude extension eftorts as being solicitation. Tou can imagine 
the county agent who ie newly assigned to a county and alta In 
his office waltlns for someone to appear and ask to be educated. 

The moat serious part of thla prohibition le that the 
hunter la not permitted to approach a rancher to ask for per- 
mission to set equipment in order to assist a nsltfibor who la 
suffering from drift of coyotes. This was the most serious 
consequence of the Leopold Report. In many cases, I believe 
that much damage could have been prevented if huntsra wars psr- 
mltted to do vrhat was necessary, not fsarfia for their jobs. 



D,g,tze:Jb.GOOg[e 



Hon-targAt spsclas are thoae that are captured inad- 
Tcrtently. They are to be released. On the surface this 
appears to be a reasonable policy but in practice it has acme 
ridiculous Interpretations. Tet, as oruch aa one may be amused, 
they create serious problems. If traps are set to prevent con- 
tinuous damage In a chicken coop from w}iat appears to be skunk 
depredation and a coyote, bobcat or fox is caught, it miBt be 
declared non-target and released. ILLlls cannot alvaya be de- 
termined exactly; but if the trapper decided that it wae a 
slcunk, so be it. lie are thankful that these people do not 
viork under constant surveillance. 

If a bobcat is determined to be a depredator In a sheep 
pasture and a coyote is caught, that coyote la non-target and 
must be released. The converse also applies, 

IX a non-target la killed by an M-44, it must be so 
reported. It must be included in the atate'a annual report 
because it has been demanded by environmental groups. They 
use these figures as a base for crittclam of the program, fhey 
refuse to pay attention to the fact that the non-target catch 
is less than 5« of the total. 

My brief reference to extension education needs further 
clarification. The intent of the Secretarial directive is 
that a staff of wildlife extension specialists in the U. S. 
Flah and Wildlife Service prepare leaflets for distribution, 
to the state Agricultural Bictensian Services. This is un- 
necessary duplication and, I believe, it may even have seme 
illegal aspects. 



D,g,tze:Jb.GOOg[e 



The land grant unlTerBltiee are the agencies having 
CongrsBslonal authorization to maintain Ifrloultural Exten- 
sion Services. In Taxaa, tho Department of Wildlife and 
Fisheries Science of Texas A & H University employs wildlife 
extension epacialists, many of whom are fully qualified and 
do ^»rlte leaflets on Animal Damage Control. In addition, they 
can and do conduct field demonstrations for the benefit of 
those who are interested in learning predator control techniques. 

I value this work because it leads to a control effort 
that does not interfere with, but actually stq;iplenentB the 
work of the professional predatory animal hunter. His mala 
Interest Is the control of problems that are severe in nature. 
Consequently, moat of the private efforts cover parts of coun- 
ties where danage Is less critical. In effect, the total effort 
becomes a means of preventive control In outside areas. I havs 
already declared this action to be essential. 

If extension education Is to be conducted it should be 
done by the state agency having legal authority to do so under 
the general direction of the U, S. Department of Igrlculture. 

In testimony you may hear from others, I am certain, that 
the Missouri and Kansas Plans will be submitted Bs examples 
of what this program can accomplish, I would like to acquaint 
you with the facts as they refer to the Missouri Plan. I have 
received this Information from Hilton Caroline who was Texas 
State Supervisor for 21 years before his retirement on March 
31, 1979. He speaks from his experience as assistant in the 



D,g,tze:Jb.GOOg[e 



BupervlSlon of tlia prograa as a U. S. Fish & VUdlife Serrlce 
smplo7«e prior to hla tranafer to Taxaa In 1950. 

An operational predator control prograiii was in effect 
for sBTeral y«ars in Misaourl prior to 1940, Since there 
were prolileme with ita lack of efficienc7, the D. 3. Flafa & 
'ifildllfe Service met with the Hisaouri A^lcultural Extension 
Service, The Missouri Wool Growers Association and the nissouri 
Conservation Connnission so that the prohlsma could be reviewed. 
It seemed to this group that under the local conditions, a 
professional hxmtar could not operate efficiently. 

At that tine Hisaouri was a famiing state. Although 
the optlnrum size for a profitable farm was 172 acrea, the aver- 
age was about 83. Today, some of them would be classed as 
being at the poverty level. 

The coyote population was located within a triangle 
having its apex at St. Louis with legs extending northwest- 
ward toward St. Joseph and southMestward to the vicinity of 
Joplln. Throughout the area coyote food was abundant. The 
Osage Orange hedges, the numerous streains, lakes and ponds, 
the lush vegetation, the straw piles and the mix of planted 
land supported a vfide variety of insects, rodents, rabbits 
and birds upon which coyotes fed. 

There were also a number of small bands of sheep along 
with dairy and beef cattle. Every farmer had his own flock 
of free-ranging chickens and turkeys. He also m£dntained more 
dogs than .necessary and allowed them to roam wherever and 
whenever they desired. 



D,g,tze:Jb.GOOg[e 



Dogs were the real problem to the hunter. Hlseotiriaaa 
of that day loved their dogs and were verj violent in their 
opposition to then being caught In traps even though thsy 
were on a neighboring or distant faun, Tr? as he would, the 
trapper was frequently unable to capture coyotes without 
interference from these animals. 

The effects of the educational program which was ini- 
tiated included denonstratione conducted undar the auspices 
of the county agricultural figent, was a decrease in the number 
of dogs subjected to traps. The reason was that a farmer 
who planned to set traps for coyotes advised hie neighbors. 
All dogs in the area were tied until the problem was solved 
for the time being and the traps removed. In many csssst the 
problem was solved as soon as the dogs were tied. 

As an aftermath of World '.far II, small farms were bou{^t 
up and converted to large ranches. The Missouri Conservation 
Commission saw that the educational had to ba supplemented 
or even replaced by the operational approach. If the Commis- 
sion had not taken the lead in the matter the original concept 
would have been a failure. 

The Kansas Flan has been widely publicized in recent years 
but its chief proponent, an avowed opponent of operational 
programs has recently realized that there is a place for each: 
operational and educational. 

In Texas, educational programs supplement the operational 
phase. They cannot replace it nor is thare any Intent that 



D,g,tze:Jb.GOOg[e 



this occur. I wish to note that in addition to the extension 
progTEtm, imder Texa« law, the iCexas Rodent emd Fredator^r 
Animal Control Service la a part of tha reaponslbillty of the 
Texaa Agricultural Sictansioa Service. That Sarvice, then is 
In the unique situation of having a hand in bo'Ui phases of 
Animal Damage Control. 

1 doubt that the situation in the public land states 
lends itself to education because educational programs, if they 
are to be effective, require that there be residents on the 
land throughout the year, this situation does not prevail in 
t2iat part of the country. 

But before an educational program can be effective, it 
must be based on unbiased facts. President Carter's Qiviron- 
mental message to Congress in 1977 contained statements which 
vje Icnou uere based upon decisions decided upon by the Council' 
on Evironmental Quality. Practically evexj manber of this 
'.Vhite House ^oup viera vrell icnown for their opposition to Animfll 
Damage Control before their appointment. (I see in the Live- 
stock w*eekly that CEQ and the Secretary's staff had purposely 
prevented him from Jmowing the truth about phases of the program 
before the Tex&s Predator Sunnit.} 

CBQ erred in their first statement which became a part 
of the Presidential message. This is the admonition that we 
much recognize and agree with the principle that predators 
are important i^ natural ecosystems. 1 agree that vegetation 
and the rodents, rabbits and browsing animals that feed v^ta. 



db.Google 



It and the predators which lElll and eat tbeae lierblvor«s 
are all part of a natural ecosjretem. Thla la true In prin- 
ciple, but onl^r "to that extent. The preniae Id that predatora 
control Todenta and that without natural predatlon upon rodenta 
there would be no vegetation. This is incorrect and mlalead- 
Ing. Predators eat rodents but they do not control them to 
any noticeable extent. On the contrary, rodenta control pre- 
dator populations. If the food supply decreosea, predatora 
decrease. The converse is, of courr<'>, also true. 

In much of central and west Texas in 19S7 and 1958, 
cotton rat numbers irrupted astronomically. The dsjaage they 
caused In vegetable, peanut, melon and grain producing areas 
in central Texas from the Sio Orande Valley north to the Red 
River was extremely serious. Predators of all species were 
abundant but the cotton rata increased for two years without 
lijDlt, It was in the second year that coyotes, raccoons, bob- 
cats, skunks, foxes and rattlesnalces flourished beyond ex- 
pectation. 

The delay in population increases in the predators was 
due to the difference in biotlc potential between anlioals 
having multiple births and multiple litters each year and 
those having multiple births but single litters. When the 
natural crash of the cotton rat cycle occurred they practically 
disappeared leaving the predators to fare as well aa thsy oonU. 
Coyotes, the most adaptable and diversified feeders among 
the predators turned their attention to sheep, goats* dear, 



D,g,tze:Jb.GOOg[e 



melons, peanuts and anything else that was edible. IhXa aoon 
put an end to the sheep industry in HaveTlck, Dlnnit and parts 
of Zarala counties. 

X wish to emphaaisa that although predators Iclll natural 
prey, they do not oontrol them. Ratural controls of real sig- 
nificance are disease, fire, flood, fanlne and similar natural 
disasters. It is true that coyotes are part of natural eco- 
systems but the part they plaj as control agents is minimal. 

As the Secretary's decisions released on November 9> 1979 
are read in their entirety it is evident that the main thrust 
la toward a reduction in the control of eoyotee. It is a bio- 
logical fact and one noted by most predatory animal hunters and 
ranchers that when there is a reduction in the nomberB of one 
predator group. It la soon replaoed by others. When coyotes 
are removed and not permitted to re-lnvade the area, and if the 
habitat is richt, which it is in most of Texas, bobcats and 
foxes will increase. To state It differently, when one pound 
of predator flesh is remoTad, It Is aoon replaced by an equal 
pound of flesh of another species. ?or example, one average 
coyote can be replaced by two bobcats or three foxes. 

The presence of predators may be a biological necsaslty 
but removal of coyotes does not cause a disaster. The smaller 
predators will increase and, except in the case of bobcats, 
these predators are much better qualified to find rodents and 
rabbits than are coyotes. More importantly, except for bob- 
cats and foxes, they are not usually serloua livestock iclllers. 



D,g,tze:Jb.GOOg[e 



Whan oorotvB bsn baas oxtlrpatod tnm local irMw 
thare irnn not baen any dlaaatrous afffots upon tha aoo^ataa 
nor do we «xp«ot rajr. Dnrlog the 2S to 30 yaora that 20 to 29 
counties In tha Xdwards Pl«ta«u had no oorojbaa after tha red 
wolf-coTota bjrbTldB Max* allnlaatad, thara waa no arldanea 
of any aeologloal problems In that unique aooaratem. She notioa- 
able reault, aside from the flonrleUng of tha sheep and goftt 
industry was the stead; Increase In white tail deer. Ihis aeau 
raoohed tha point where there was a shootable anrplua. 

This le&da to a oritlolsm of another stfttament mada b^ 
the Counoil on fiiTlronnental Qualitr. I iinotat "Soientiflo 
wildlife manasetiient IhTolvaa taUng, at naxiaum, only Uit In- 
tended target aniaals. " This is not corract. Wildlife aaaa(ars 
manage wildlife such as deer and <iu£d.l, to name only two, to 
tho aztent that there will be a ehootabls surplua. Zhla ia 
not a case of "the intended target aninal". 

Wildlife managemeat for aporting purpoaes, and that la 
what license holders are interested In, la for purppaas of rt- 
oreation. If there were no Interest In hunting or fishing there 
would be no need for management. Sut since Interest In these 
outdoor sports Is as great as it is there will be need for wild- 
life managers to manage so that there will be a surplus of tlis 
game snd fish they prefer. 

I should point out that the hunters throng the rittaaa 
Robertson let and flehexnen urough the Slngell let pay for 
their sport. The environmentalists pay for nothing other than 
their law suite. The Pittman Robertaon Bill was challenged 
by that group thia paat year, 



D,g,tze:Jb.GOOg[e 



I have dwelt upon this Ui«i>a becf>"se we need to place 
the natural ecosyBten principle in proper perspectiTS, 

The facts are that there are not, if there over were, 
any natural ecosyBtems. The natural acosystem ebbs and riows 
as do the tides. The system la controlled by forces such as 
those I hare listed, if huuaalty is to exist; if there is to 
be a shootable surplus; if we are to raise food and fiber for 
food and clothing or trees for our dwellings, we must manage 
for the etirplus, or more correctly - ■» anstalned yield. 
Because of this, it is apparent that we live not in a natural 
ecosystem but in a managed ecosystem. 

The farmers and ranchers who are the most euocaseful 
are those who clearly understand the eooayetein In which they 
live and manage it to the full extent of their c^tabllity. 

The trends in Secretary Andrus' decieicns as well aa 
that of the Leopold and Cain reports are diractad toward no 
management. The real implication and one we have heard many 
tines from our detractors, is no sheep. Animal Damage Control 
personnel have been told that if the program c- , to an end, 
the sheep industry would expire and that would be good for 
the countryr This assumption is not true, we need more food 
and fiber - not less. 

Studies conducted by the Economic, Statistics and Co- 
operative Service of the U. S, Department of Agriculture reve«l 
that financial losses to the sheep industry approxlnate 



D,g,tze:Jb.GOOg[e 



330,000,000 each Tear of tha 4360,000,000 yearly Induatry total. 
The loss to conaumeTB due to both sbeep and lamb pradatlon 
approzlmatee 110,000,000, Thie researoh also revaalad that 
the benefit derived from an Increaee in control of the major 
predators in areas of serious sheep, lamb aad calf production 
would exceed the additional costs of control. Estimated num- 
bers of sheep and lanb kills range in the 1,250,000 braoket. 

About one third of the sheep produoere in the West and 
Southwest lose in excess of 59i and ona fourth lose lOK of their 
lamb crop to coyotes. In the same area, calf loaees reach as 
high as 3.1% each year. In Texas, death losses of sheep and 
lambs due to predators amounted to ^8% of all deaths in 1978 
compared to 25?d in 1967. Coyotes were the largest single 
cause of death losses during 197B accounting for 24?i of all 
sheep and lamb deaths. Ooat and kid losses in 1978 due to 
predators amounted to l&i of all deaths compared to i^ in 
1967. Coyotes were responsible for 24.% of tiie total death 
losses to predators during 1978, followed by eagles which killed 
20» and bobcats which kiUed ISK. 

These are losses over vrtilch the individual rancher has 
little or no control without professional assistance. 

Such losses are not new to many famsra and ranchers. 
In Texas, In 1915 losses averaged loji even at a time when 
coyotes vere fewer in number. Through federal, state and 
Association action, losses were reduced to an average of 3?( In 
the 15 years of operation since 1915, 



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of Q«lcnlftt«d aogllgwieo and obBtmotlpra 'by tbm Dapiu tiint 
aad the SerTlo*^ Xoaaaa siw i^proxlBate titoaa of tho World 
War I era. 

It bad not been my latantlon to Inolvido all this detail 
in mj praamtation but I fael It to be eaaantlal that the facta 
of the Texas situation are known to tout Couilttee. I have 
studied the raatter carefully and have decided that U.3*I>.I* 
does not intend to conduct a viable inlmal Damage Oontrol program. 
Z present In eridanee tha situation in which the 0. S. ?iah 
and Vlldllfs Service finds itself. This la explained In letters 
written to Secretary Cecil O. Andrua and Director J^nn Oreenwalt 
by Hilton Carolina, G!exas State Supervisor (retired] and now 
our jLsbc elation* a Public Relations Conaultant (Bshlblts A & B). 
Mr. Caroline's report to me on the baaio 
elements of the etatenents by Secretary indrus, Steven Jellinelc 
of E,P.A. and Mrs. Amentrout of the Rational Audubon Society 
at the Predator Summit arranged by Texas Departraent of Agri- 
culture Commissioner Reagan n. Brown, is contained In 
£i:tilblt 0. EEhlblt D Is our Position Statment on Secretary 
Andrus' decisions. 

?or years we have been Interested In removing the Divi- 
sion of Animal Damage Control (formerly Division of Predator 
and Rodent Control) from direction by U.S. D.I. and having it 
transferred to U. S. D. A. On March 26, 1963, when we raalisad 
the full thrust of the Leopold Report, our Association introduced 
a resolution for consideration by the Texas Sheep and Qoat 
Raisers Board of Directors (Exhibit S). 



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On A^ll 2S, 1969, Smator Tower latrodueod In the 
first sesalon of the 89th Congress a bill (S.1B35} tc pro- 
vide for the tranafer of the Division of Predator Ccmtrol 
from the Department of Interior to ths Deparlaont of Agri- 
culture (Exhibit 7). It was referred to the Comilttee on 
Commerce. (It did not have the full support of western sheep- 
men who grased their flocks on Interior laads notwlthstan d ing 
the Taylor Grazing Act.) 

In my opinion and that of the Directors of the Texas 
Animal Damage Control Association there does not appear to 
be any future for our industry if we are to depend upon the 
federal goTemment. We feel that even though federal funds 
would be lost. It would be in our best interest to cancel the 
,l>Iaster Cooperative Agreement with D. S.D.I. In anticipation 
of what we may be forced to do we have prepared a contingency 
plan which is now under review by our Directors (Bihlbit S). 

Recently, we received copies of bille presented by 
Senator Tower and Representatives Kazen and de la Carsa. 
Since they represent a step in the right direotlon, we endorssd 
than In letters I wrote to our Texas Senators and Sspresen- 
tatives. At least these bills put U.S. D.I. on notice that the 
Congress is not satisfied with ths department's handling of 
the Act of Harch 2, 1931. 

We hope these bills will be eerioualy considered in the 
Congress but our experience is such that we have little faith 
In D. s. D. I. ve feel that an iMMdiato transfer to U.S.D.A. 
Is badly needed. In that agency onr budget requasts and 
other matters will be heard by snoh Congresalonal Oomittees 
as your committee on Agriculture. 

I appreciate having the opportunity to place oxa posi- 
tion in the record. 

(TIm uhlblta T*f«rr«d to ar* hald Iji tha aabcoBlCCM flLa.) 



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Intflfnattonal AHOCiatlon 

ol 

Flih and Wlldllla Aganclaa 



Bonotablft KUot ds Ia GatzAi CJvtlmm 

Subcczmittiee en Departmsnt Investigations, 

OfiersiicAtt, and ntr^nrdi 

Ikiuse Agriculture Ctumittae 

1301 IdKiuorth Soaae Office Building 

Itashingtcn, DC 20515 

Dear Ctngresonan de le Garza: 

Ilie International Associaticxi c£ Fish and wildlife Agencies is 
a voluntary oiganizaticn '''fT"'"*^ of fi^ and wildlife agencies in 
the Uiited States, Canada, and Mexico, including tie fiah ar^ wild- 
life agencies of all 50 states. Kb are vitally interested in the 
subject of animal danage cc ntr ol vdiidi ycur Subcamittee held hear— 
ings en April 16 and 17, loid request that the enclosed statoDcnt be 
included in the reocud of the hearing. 

The recmmfindat.iCTiB oontained in the testincc^ ucre originally 
dEMeloped fcy the AsBociaticn's standing Ccnnittee en Predator Policy 
idilcti has been active since 1969. Die ""^'"w—^f f ing were adcpted 
by the Associaticn in 1971, reaffirmed in 1977 and in ftardi of 1960. 

I beliEue the atatanent, whicdi reisreBents the best pzofesslcnal 
wildlife ranagenent judgements of this Associaticn will be useful to 
you in ccnsjdering the future of the Animal Danage Ocntrol ProgEaB. 



Emurtve Via 






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C of Che Internatlonil AscocUcion of Fl*h and Wlldlif* Agcnclaa 
erslghc hearing an Anliul Damaga Concrol before th« Sanat* Con- 
n Envtcoiunenc and Public Uorka. April 24 and 15, 1980, Haihlog- 



altnan, I am Robert J. Tully of Denver, Color 
Ccntrol Policy Conniiccee of the Int 
fe Agencies. The InCernaclonal Aasa 
includes the Flih and Wildlife Agenc 



uefflber of Che Animal 



The folloulng position stateovencs uer 
A»soela[Llan during 1977 to guide the 
policies from the state Hlldllfe agen 



cdlnatlon bet«e 
dltlon this Com 



wildlife agenc 
through per for 
agents. The n 



moiC efficient and humane manner, 

ivlronmantal hazards, ■ qualified public 
adolnlster animal daoiage control program 

leed for development and use of moce af- 
Clol luethods provldea Justification for 



(c) The nature and scope of an animsl damage control program should 
be defined by an agreement bet»een the individual states' wild- 
life agencies and the u. S. Fish and Wildlife Service, ulch the 
gtatea exercising an option to accept or reject offered faderal 
assistance. 

(d) Wildlife agenciea in states that accept federal servlcea ahould 



nstblllcy for s control progra 



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10 The 1967 Animal Damage Control Policy of Che U.S. Bureau of 
Spoct Fisheries and Wildlife (FUJS) provides an oppoctimicy 

of conflict with or hazard to natural resources or human uelfara. 

■ 1978, Jack R. Gtleb. Chairman of our Predatory Policy Coaanlttee 
I an Che Secretary ot Interior's Animal Damage Control Policy Advisory 
:ree and inade the following recoinnendaClans in behalf of the Assoclati 
msideratlon by the Secretary and by the Fish and Wildlife Service. 



ill but signlfice 



t of this nation 






should specify Q 
9. Lethal and non-l 



I be done on the basis of an annual animal 
ich state, promulgated each yeac vith adcqu 

illdllfe agency, U.S. Fish and Wildlife Ser 
■at Service and Bureau of Land Management. 



Ic compounda must be authorised by EPA t 
ivenesB and Identify potential problems, 
i by the Fish and Wildlife Service on an 



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I ADC funding Co III Che need for 



:ol Diechoda foi 



C fiv* (S) 

se In Che pcoper 



eluded. 

n upgrading h 



irove Che supply 



■lechal cechnlque 
«1 ceehniques. 



1 tar nEH lethal c 



Ij', in 197B and 1979, 



lelopmenc of Che Drafc and In neklng 



:e'9 Hamoiallan Predator Damage Hanageuient for LI 

1 ctiac Che Secrecary of InCerlor adopc Alee 

f all CurrEDt ConCrol Techniques) ulch che addli 

le offending animal uheo possible as che BoaC vl 



iral policy decisions, 
8. 1979, are of eKCce 
lecause of chE. coopera 



with Che Federal gove 



staces, Chrough chelr wildlife 
9ses boch, have been full co- 
r fifty years. We alsn consider 
on noC only Che agriculture 
species of resident wildlife 

md che Depaccmenc of Interior. 



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ariglnslly recngnlied in the policy meoiorandum, Ue "ere not Included 
he estibllshment of the Interagency uoiklng group noc uere the statei 
[oned as part of the Research Aduisory Committee aa uis the ILveatock 
BCry and the environmental community. SecenCly Secretary Andrua assured 
tiat he did not Intend to exclude the states and proposed representation 
a State Conservation Agency on Che Beaearch Advisory Conmltce*. Seece- 
Andrus also advised chat he would aoon be requesting addlclonal as- 

operatlonsl activities con ... 

states wish to remain a full parcnet and desire Co condnua in Cheir 
porclve rote touard program accompllshaent so that resident wildlife and 
public will benefit according to the needs of the individual state. 

■ position on a nunber of apecific 



Bstgnated as thre 



Z. The Internatl 
tool for use 



.es that predaeldea should remain a vUbla 
preventive and corrective damage control 
I recommends that the Fish and Hlldllfe 
:h and field tesCing of Compound lOSO la 
.p single dose baicing cechniquea Co 
lacldea and research, develop and field 
ill and delivery systems which are selectlv 



:be toxic collar, dei 
laleccively deliver | 

iffeccive and efflcieni 



The International gcrongly apODses any crans£er of authority for 
Department of Agriculture. 



■nd on effec 
both public 



e correcCive dan. 
orcunity for fai 






cooperation with Che state wildlife and sti 
plication on both public and private lands. 

rhe International Asaociaclon, rapcasencing the wildli 
Control Program through continued rei 



ellave federal policy 

clve actlvitlea on 

ter must include lethal 



tencies of the 
lo to Secretary Andr 
updated Animal Dama 



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1 






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DATE DUE 





































































































STANFORD UNIVERSITY I 
STANFORD, CAUFORNIA 943C 



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