LETTER TO USFWS REGARDING RULE TO BAN
PREDATOR CONTROL ON NATIONAL WILDLIFE REFUGES
February 2024
Ms. Shannon Estenoz
Assistant Secretary for Fish and Wildlife and Parks
U.S. Department of the Interior
Re: Ban predator control on the USFWS’s more than 560 National Wildlife Refuges
Dear Assistant Secretary Estenoz:
On behalf of the Humane Society Veterinary Medical Association and the ### undersigned veterinarians from across the U.S., we are pleased to submit these comments in support of the proposed rule, National Wildlife Refuge System; Biological Integrity, Diversity, and Environmental Health (89 FR 7345) concerning the U.S. Fish and Wildlife Service’s proposal to ban predator control on these publicly-owned federal lands.
As veterinary professionals, we recognize that methods used to conduct predator control, particularly hounding, baiting and trapping as described below, are stressful, injurious, and deadly not only to wild animals but also to companion animals.
- Using human-food baits such as meat threatens wildlife and should not be permitted on wildlife refuges. Experts agree that baiting wildlife causes animals to concentrate in one area, increasing the potential for the spread of disease, including rabies.[1] Bait poses health hazards to wildlife because of decaying meats or other foods and toxicities. Additionally, bait sites cause predation on unsuspecting smaller non-target animals.[2]
- Packs of radio-collared hounds should not be permitted to hunt on wildlife refuges because these hounds harm non-target wildlife including young animals and farm animals.[3] It is not uncommon for fights between the hounds and their prey to occur—causing injuries and death to either hounds and/or wildlife.[4] Chasing wildlife with hounds can result in heat exhaustion or stroke for both hounds and the wildlife they pursue.[5]
- Traps are notoriously indiscriminate and can capture, injure and kill any animal, including companion dogs and cats, especially near urban settings or on trails.[6] Traps set for one species can badly maim or cause life-threatening injuries in others.[7] So-called kill traps frequently fail to humanely kill animals.[8] Wolves and other animals caught in neck snares can suffer for days or even weeks before they die.[9] Bears suffer immensely when captured in snares as they struggle to escape.[10] Trapped animals experience agony, shock, trauma and dehydration until killed or suffer death from starvation.[11] Animals caught in traps suffer from broken limbs and teeth, dislocations, hemorrhaging, and loss of digits, paws, legs and multiple other unacceptable problems.[12]
We thank the U.S. Fish and Wildlife Service for proposing a rule that will eliminate these inhumane predator control methods and reduce pain and suffering for animals on our nation’s wildlife refuges.
Sincerely yours,
[1] L. Dunkley and M.R.L. Cattet, "A Comprehensive Review of the Ecological and Human Social Effects of Artificial Feeding and Baiting of Wildlife," (2003); R.A. Inslerman et al., "Baiting and Supplemental Feeding of Game Wildlife Species. The Wildlife Society.," (2006).
[2] "Consumption of Intentional Food Subsidies by a Hunted Carnivore."
[3] Hank Hristienko and Jr. McDonald, John E., "Going in the 21st Century: A Perspective on Trends and Controversies in the Management of the Black Bear " Ursus 18, no. 1 (2007).
[4] Ibid.; Stefano Grignolio et al., "Effects of Hunting with Hounds on a Non-Target Species Living on the Edge of a Protected Area," Biological Conservation 144, no. 1 (2011); Emiliano Mori, "Porcupines in the Landscape of Fear: Effect of Hunting with Dogs on the Behaviour of a Non-Target Species," Mammal Research 62, no. 3 (2017); L. M. Elbroch et al., "Trailing Hounds Vs Foot Snares: Comparing Injuries to Pumas Puma Concolor Captured in Chilean Patagonia," Wildlife Biology 19, no. 2 (2013).
[5] Thomas D. Beck et al., "Sociological and Ethical Considerations of Black Bear Hunting," Proceedings of the Western Black Bear Workshop 5 (1995).
[6] Kimberly A. Villeneuve and Gilbert Proulx, "Impact of Wild Mammal Trapping on Dogs and Cats: A Search into an Unmindful and Undisclosed World," in Mammal Trapping: Wildlife Management, Animal Welfare and International Standards, ed. G. Proulx (Alpha Wildlife Publication, 2022).
[7] Clayton Lamb et al., "Considerations for Furbearer Trapping Regulations to Prevent Grizzly Bear Toe Amputation and Injury," Wildlife Society Bulletin (2022).
[8] G. Proulx and D. Rodtka, "Killing Traps and Snares in North America: The Need for Stricter Checking Time Periods," Animals 9, no. 8 (2019).
[9] G. Proulx et al., "Humaneness and Selectivity of Killing Neck Snares Used to Capture Canids in Canada: A Review," Canadian Wildlife Biology and Management 4, no. 1 (2015).
[10] M. Cattet et al., "An Evaluation of Long-Term Capture Effects in Ursids: Implications for Wildlife Welfare and Research," Journal of Mammalogy 89, no. 4 (2008); R.A. Powell, "Evaluating Welfare of American Black Bears (Ursus Americanus) Captured in Foot Snare and in Winter Dens," ibid.86 (2005).
[11] Cattet et al., "An Evaluation of Long-Term Capture Effects in Ursids: Implications for Wildlife Welfare and Research."; Proulx et al., "Humaneness and Selectivity of Killing Neck Snares Used to Capture Canids in Canada: A Review."; G. Iossa, C. D. Soulsbury, and S. Harris, "Mammal Trapping: A Review of Animal Welfare Standards of Killing and Restraining Traps," Animal Welfare 16, no. 3 (2007); Powell, "Evaluating Welfare of American Black Bears (Ursus Americanus) Captured in Foot Snare and in Winter Dens."
[12] Cattet et al., "An Evaluation of Long-Term Capture Effects in Ursids: Implications for Wildlife Welfare and Research."; Iossa, Soulsbury, and Harris, "Mammal Trapping: A Review of Animal Welfare Standards of Killing and Restraining Traps."; Powell, "Evaluating Welfare of American Black Bears (Ursus Americanus) Captured in Foot Snare and in Winter Dens."
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