UPDATE: Comment Period Extended on Predator Killing Contest Environmental Assessment
UPDATE 10/17/2014: Due to a request by Representative Peter DeFazio of Oregon, the comment period has been extended until Midnight Mountain Time, THURSDAY, OCTOBER 23, 2014.
The BLM is asking for comments on an Environmental Assessment that examines the impacts of issuing a Special Recreation Permit (SRP) to conduct a predator killing contest on BLM lands. The comment period begins today and remains open for
15 21 days, until Thursday, October 16, 2014 THURSDAY, OCTOBER 23, 2014.
If the SRP is issued, the killing contest is scheduled to take place from January 2-4, 2015 and would include prizes for killing a variety of species from wolves, coyotes, weasels, skunks, jackrabbits, raccoons, and starlings. Last year the contestants killed 21 coyotes and at least one badger. The permit would allow the contest to take place on BLM lands in a large portion of eastern Idaho.
According to the Environmental Assessment, the BLM received “[a]pproximately 56,500 comments were received during the scoping period. Roughly 56,490 commentors indicated opposition to the event; most of these letters were copies of nine different form letters that expressed general disapproval of a hunting derby wherever it is held. Approximately 500 unique/personalized comments were received.” This means that there were only 10 comments in support of the permit being issued.
The Environmental Assessment was written in a manner that signals that the BLM is likely to issue the permit by giving much weight to the custom and culture of Salmon, Idaho and surrounding areas despite the fact that issuing the permit is likely to give the State of Idaho another black eye and affect tourism in the state. The economic analysis found that while the town of Salmon and surrounding areas might receive a $94,000 boost, the state as a whole could miss out on anywhere from $23,800 to $2,380,000 depending on how many people decide to not visit the state due to its draconian predator management policies. Admittedly, it is hard to quantify exactly how much the state will lose in economic activity but, because the world press has focused on Idaho’s wolf and predator management recently, it is clear that Idaho has a very poor image among those who value wildlife and would come to visit the state to see it.
Fails to Examine Competing SRP Request
The Environmental Assessment failed to adequately address an alternative SRP request for a wildlife viewing contest submitted by Western Watersheds Project and Center for Biological Diversity which, if the permit is issued, would take place instead of the derby or at the same time. The Environmental Assessment merely mentions the competing SRP and fails to consider or propose to deny the derby permit and approve the wildlife viewing context permit, or another alternative to allow both events during the same weekend.
Even if the BLM were to issue the competing SRP for the wildlife viewing contest but require it to take place either before or after the predator killing contest, there was no assessment of the inherent conflicts of the two. If the wildlife viewing contest were to take place before the predator killing contest then participants would be injured by knowing that wildlife they viewed could likely be killed for the bloodlust of the killing contest participants. If the wildlife viewing contest were to take place after the predator killing contest then participants would be injured because there would be less possibility of seeing predators on the landscape.
To submit comments, the BLM has these suggestions:
When submitting comments, please focus on issues under BLM’s authority, i.e., impacts to recreation, wildlife habitat, social and economic values. The BLM does not manage for wildlife or determine hunting regulations. Please submit comments by mail to:
BLM Idaho Salmon Field Office
Attention: Predator Hunt Derby SRP
1206 S. Challis Street
Salmon, ID 83467
or by email at BLM_ID_Predatorhuntderby@blm.gov. The BLM will accept comments until October 16, 2014. For more information on the SRP application, contact the BLM Idaho Salmon Field Office at 208-756-5425.
Another Avenue to Express Concerns
Another avenue to express concerns is to contact the Idaho Department of Fish and Game Commission to ask that such predator killing contests not be allowed in Idaho. The Commission, as well as BLM, has authority to stop these contests in Idaho. Make it known that Idaho has a duty to manage all wildlife under the public trust doctrine and that allowing these types of killing contests only serves to further tarnish the image of the State of Idaho.
The Idaho Department of Fish and Game Commission adopted a Predator Management Policy in 2000 that states:
Fish and Game will not support any contests or similar activities involving the taking of predators which may portray hunting in an unethical fashion, devalue the predator, and which may be offensive to the general public.
Clearly, these contests are offensive to the general public, they devalue predators, and portray hunting in an unethical fashion.
The Idaho Department of Fish and Game has elaborated on this policy and acknowledged it does have the ability to restrict or require permits for these types of events.
Why is killing wildlife … state resources…(for prizes) okay for private individuals to make money? This seems wrong on all counts. | Idaho Fish and Game
Q: Why is it that private individuals can personally profit from killing resources in a carnival-like atmosphere? Resources that belong to everyone? Are you aware of how you are offending so many people?
A: Idaho Fish and Game has not been asked and will not provide any financial support or logistical support for this event.
13 years ago, the Idaho Fish and Game Commission adopted a Predator Management Policy that states “Fish and Game will not support any contests or similar activities involving the taking of predators which may portray hunting in an unethical fashion, devalue the predator, and which may be offensive to the general public.”
All participants are still required to obey the rules and current season frameworks such as season, method of take, licensing and reporting just like participants in a big buck contest. Fish and Game will conduct routine patrols to ensure current hunting rules and seasons are being followed. If there are reports of unlawful activity associated with this derby or any other hunting activity, Fish and Game will investigate.
Fish and Game serves as the public trust manager for Idaho’s wildlife. The agency takes direction from the trustees – the Fish and Game Commission, the Governor and the Legislature. If they decide to restrict or require permits for these types of activities, then Fish and Game will implement those policy decisions.
You can contact the Idaho Department of Fish and Game Commission visit this page where the contact information for the current Commission is posted: https://fishandgame.idaho.gov/public/about/commission/?getPage=183
The U.S. Forest Service Double Standard
The U.S. Forest Service last year decided that a Special Use Permit (SUP) was not required for the contest to be held on U.S. Forest Service lands in Idaho. Shortly after this arbitrary decision was challenged in court, the Malheur National Forest in Oregon informed another contest organizer that they would have to initiate the process to obtain the SUP to hold the contest on U.S. Forest Service lands.
You can contact the Salmon-Challis National Forest in Idaho and request that a SUP be required for this contest.
Salmon-Challis National Forest Supervisor’s Office
1206 S. Challis Street
Salmon, ID 83467
Or contact them via their website: http://www.fs.usda.gov/contactus/scnf/about-forest/contactus
Ken Cole is a 5th generation Idahoan, an avid fly fisherman, wildlife enthusiast, and photographer. He is the interim Idaho Director for Western Watersheds Project. We do not accept unsolicited “guest” authors or advertising.
84 Responses to UPDATE: Comment Period Extended on Predator Killing Contest Environmental Assessment
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Ken, thank you for the update. I spread it across the I-net.
Probably posted here a year or so ago, but needs to be posted again when it comes to coyote/wolf killing contests:
“You’re not going to make money at it,” he says. “It’s a hobby-type thing.”
“participants would be injured”.
You keep using that word….
“injured” – to wrong or offend.
I am confused as to why BLM, which operates under similar statutes as USFS which has taken the position no permit is required as I recall (especially after a court decision in their favor), to manage land and vegetation, feels a special use permit is required for this event. BLM admits it has no responsibilities to manage wildlife (deferring to the state of ID), and the “economic impacts” fuzzy as they are don’t really rise to some “significant federal action” – they are really doing nothing other than allowing access, which is already permissible. OK, so there may be as many as 500 participants on how many hundreds of thousands/millions of acres in the affected area? There are more than that by a factor of 10 in summer and hunting seasons.
And, let’s be candid, the “competing” WWP, CBD “wildlife viewing event” is really an obstructionist attempt to stop the event, which is probably why they only mention the proposal in passing.
I am curious, what are the federally “threatened species” in the functional geographic area of this event? And, how will such a low volume human hunting presence for only 2 days adversely affect habitat, even if they do remove some predators at or slightly above the number taken last year (as I understand it no wolves were taken and only a few coyotes).
Frankly, I think they will issue the permit with very few if any restrictions, especially if no “official activity” such as sale of tickets or awards of any sort occur on BLM land. This is a CYA exercise.
Again, I don’t support these events (actually I detest them), but find it difficult to understand ANY federal oversight, and especially a permit at this use level.
I assumed it was a dog and pony show, and yes, to CYA.
Who here believes they will not issue the slaughter-fest permit?
Simply put, BLM policy requires permitting.
“Under the authority of Federal Lands Recreation Enhancement Act (REA), the BLM uses the recreation permitting system to satisfy recreational demand within allowable use levels in an equitable, safe, and enjoyable manner while minimizing adverse resource impacts and user conflicts.”
“I am curious, what are the federally “threatened species” in the functional geographic area of this event?”
This info is in the EA under “Wildlife, Threatened/Endangered Animals, Sensitive Animals, and Migratory Birds.”
++Simply put, BLM policy requires permitting.++
That is a legal question, and I am not sure of the answer(statute>regulations>policy). Sometimes agency policy is different from statutory authority, and even consistency as among different management areas/regions. Is there a similar EA for hunting, generally, which occurs every single year, but sometimes with season adjustments, because the interesting thing is that some of these people might be there anyway? I don’t think it would be likely BLM would deny or could even deny land access generally unless there were a vegetation issue. This is an already allowed recreation hunting season. The event itself is something different, and BLM likely only be measuring ADDITIONAL incremental impacts that new any new dimensions/issues it raises for the 3 days of the event ON BLM land, and only BLM land.
The query from the Scoping letter for the EA asks only for public comment on “threatened species,” but broadly construed it may include the other heading categories you note, I suppose, but it still seems that is more the purview of IDFG, or another federal agency (would they seek consultation from FWS?) if not an actively listed federal species (of course migratory birds might be).
As a former BLM NEPA specialist, I think the BLM District Manager (DM) realized the potential controversy of the event and thus sent a scoping letter to determine the extent of public interest. After receiving over 56,490 comments in opposition and only 10 in favor, the DM determined the event did not meet a categorical exclusion (due to controversy) and to go forth with a EA and FONSI.
A SRP allows the BLM to require the sponsor(s) to provide health and environmental protection stipulations. I know allowing up to 500 participants scattered within a large area for two days does not typically result in environmental degradation, but it is a legal document to CYA. Even though the event did not warrant a EA and FONSI, the DM may have chosen to go forth with it knowing in todays world of litigation, its better to be safe than sorry. A event similar to this was recently litigated successfully in Oregon on the grounds that it constituted gambling as participants were awarded prize money.
Is it a CYA and will the BLM issue a permit, probably yes on both accounts, but I will comment on it anyway.
Okay, that is much more professional than stating it is a ‘dog and pony show’. Thank you for your input, Gary. This makes sense.
With an event like this, where the sponsor really has no “organized” assembly of people, all acting on their own independently, what kind of “health and environmental protection” assurances could a sponsor provide? (Again, it is my understanding any gathering, sale of tickets or award of prizes would not occur on BLM land). That is why I am having a difficult time understanding why BLM wants to address what appears to be a tar baby.
Do you have a cite to the OR case, or can you give more facts that might distinguish or show similarity of the events. Does the BLM have any legal authority to regulate “gambling” if the transactions do not occur on BLM land?
WM, As the BLM fact sheet mentions, the SRP will allow the BLM to control visitor use, protect recreational and natural resources, and provide for the health and safety of visitors. It will include information such as how many participants, map(s) of the derby area, sanitary requirements and off road use restrictions. In my experience, organizers sometimes request the use of staging areas on BLM land, where large groups of participants meet, thus requiring health and safety (ie. port-a-potty, and cleanup) requirements.
Here is the link to the Oregon case. No the BLM does not have legal authority to, regulate gambling that does not occur on BLM managed land. I only mentioned it as a historical precedent for a similar action regarding this proposed derby.
In Oregon, it was a state law prohibiting unlicensed gambling that banned the predator killing contest there. The state laws stopped the “contest” not the feds. Project Coyote was one of the successful litigators.
These indiscriminate slaughters of wildlife are beyond the pale, and should be immediately outlawed across the country. Not only are they cruel, they are ineffective, often only exacerbating the perceived problem. Every state has depredation permits. Use those instead, when absolutely necessary.
California (as usual) will most likely be the first state to ban predator killing contests, at the December 2014 meeting of the CA Fish & Game Commission. Hopefully, after California shows the way, many other states will follow.
For those of you that truly have no clue what goes on in the forests of Idaho, Washington & Montana, let me give you an idea. Our wildlife has been completely decimated by predators over the last 19 years. The most severe impact has been by the introduction of wolves into Idaho & Montana and by not allowing the use of hounds in WA state. I live here, hunt here and have seen the devastation first hand. It really bothers me when I see posts like this and hundreds of comments by folks that are a 1,000 miles away, stuck in their cardboard box in the middle of a 500K+ populated area. The elk in Idaho & Montana are gone. Deer, gone. Moose, gone. I still can’t figure out what the FWS agenda was with the introduction of the horrible predators, but they had to have known of the impact on our ungulates. As far as this derby goes, I think they should take it from 3 days and extend it through the end of the month. Our predators are so overpopulated that we have now had human attacks in Idaho and WA state.
So, before you go running your mouth on something you have absolutely no clue about and have zero experience in, think about what REALLY goes on in these states and keep your comments to yourself. Or perhaps a new rifle, tag and a 10 day hunting trip in southern Idaho will change your views on wildlife.
It is you who are uninformed. Many of the people who comment here live in Idaho, Montana, Wyoming, Utah. The webmasters live in Idaho. Predators have had little negative effect on wildlife in Idaho. Your comment that there have been human attacks by wolves in Idaho and Washington are flat out wrong. If there had been, it would be all over the local news here.
Now when the hell did I say that there have been human attacks in WA state? Never. What I said was VERY clear, I was stalked in the Salmon Creek Wilderness in Idaho. Wow, you guys truly are professionals word-twisters. I shouldn’t be surprised…you still believe that there’s never been human attacks. Well believe what you want, it’s only a matter of time.
Luke says: “Our predators are so overpopulated that we have now had human attacks in Idaho and WA state.”
Ralph replies: “Your comment that there have been human attacks by wolves in Idaho and Washington are flat out wrong. If there had been, it would be all over the local news here.
Luke contradicts self and digs deeper hole:”Now when the hell did I say that there have been human attacks in WA state? Never. What I said was VERY clear, I was stalked in the Salmon Creek Wilderness in Idaho. Wow, you guys truly are professionals word-twisters. I shouldn’t be surprised…you still believe that there’s never been human attacks. Well believe what you want, it’s only a matter of time.”
There is no “Salmon Creek Wilderness”.
Define little negative effect and prove it on paper by IDFG reports. Then I will buy into your lies. You know just as well as I do that the elk population has been damaged to the point where it may never recover. Stop living a lie and tell the truth. Stop believing crazy opionion based forums and blogs and read the facts. There’s nothing to argue here. Predators wiped out the ungulates in Idaho – fact.
Idaho Elk Reports: http://fishandgame.idaho.gov/ifwis/huntplanner/stats.aspx?season=general&game=elk&yr=2013#elk
Gosh Luke, apparently Idaho continues to not only have elk seasons, but in fact, they have so many elk that they feel the need to hold controlled hunts… fact.
“It is likely that elk populations are influenced by a complex combination of habitat condition/characteristics and predator systems. It is also likely that temporal changes in weather
patterns and precipitation affect the relative role of habitat and predators.”
There you have it–straight from IDF&G. Sounds like just maybe the relatively minor decrease in Idaho’s elk population is not solely attributable to wolves. 😉
“Wolves have long been blamed for elk deaths in Idaho. But research is showing the predators have gotten a bum rap.
In its August newsletter, the Idaho Department of Fish and Game summarized recent elk studies and found only a minority of elk populations are declining and wolves are culprits in few.”
“Idaho data: Three years of relatively mild winters have allowed mule deer populations to recover in 2014 to some of their highest levels since the early 2000’s when hard winters and habitat loss brought the mule deer numbers down to a level that in 2004”
“Moose in Washington appear to be bucking the decline that’s plaguing the animals across most of the lower 48 states, a Washington Fish and Wildlife Department biologist says.
Rich Harris, the agency’s new special species manager hired last year, says annual aerial surveys and hunter success rates indicate moose numbers are at least holding steady while moose continue to expand their range westward in the state.”
“Idaho, however, is reporting declines in moose, primarily in the Panhandle and northcentral region where wolf packs have been revived.
Dave Koehler, Idaho Fish and Game Department wildlife biologist in Lewiston, said while predators are part of the problem, they may not be the most important factor. Citing moose studies in other states, he said habitat changes, parasites and warmer temperatures related to climate changes are believed to be major drivers of the decline.
“I’m not saying wolves are not having an impact on moose recruitment, but it’s not as simple as saying they are the problem,” he said.”
“The elk in Idaho & Montana are gone. Deer, gone. Moose, gone. ”
Three strikes and your out.
Have any of you looked at the data behind the elk population in Idaho and Montana? The FWS offers endless reports of elk counts and an annual report that CLEARLY shows the impact wolves have had on ungulates. The moose in WA state are at their peak, agreed. However, we’ve only had wolves for two to three years now. Started out with one breeding pair and sitting close to ten now. The heaviest moose areas are in Stevens county, highest county in history. Wolves just moved in this year…let’s touch on this subject again in say 12-24 months. I guarantee you they won’t be issuing 33-40 tags like they do now.
“Our wildlife has been completely decimated by predators over the last 19 years.”
Are predators not wildlife?
As for your comment. It’s bullshit. Before my nephew was paralyzed in an accident last Dec. he killed one elk per year for his meat source, which was more than enough, so he shared. He has cousins and uncles that do the same. I know one of my nephew’s cousins likes to hunt and he is a great hunter. He usually kills more than one, but he then donates that meat to other tribal members. When there is a funeral then someone (my nephew was often the designated hunter) takes an elk and the meat is used to feed everyone at the funeral. This is in Oregon. The “wildlife have been decimated by predators”. The elk are there if you are a half azzed decent hunter.
How is it bullshit exactly? They closed Lolo Pass to hunting until who knows when. Gardiner, MT was also closed this year. Do you know what the cause was? Let me spell it out for you.. W O L V E S. Their is no other explanation and countless documents proving this point. We’ve spent 30-40 years carefully managing elk herds in WA, ID & MT and now they’re closing our hunting areas? And you guys wanna blame it on winter kill? I don’t think so. It’s as clear as day what the underline issue is. As far as my hunting skills go, I think they’re perfectly fine and improving every year. Shot a beautiful bull Monday with a muzzleloader, just cut the meat up and will happily stock my freezer to feed my family for the next 6-8 months. p.s. I also serve on the Big Game Recovery committee in Spokane, WA. We take wounded game that will not survive, end their suffering and all of the proceeds go to the Union Gospel Mission. Yep, close to 9,000 lbs of meat went to the homeless last year. Going to be pretty hard to paint a picture of a sportsman like me that as a “half azzed decent hunter.” Back to the subject at hand; the derby. Do I participate, no. Do I support it, yes. I don’t have a choice. The wolves are numbering close to 1,700 strong now and the bulls don’t even bugle anymore. Cow/calf ratios are below 5%, lowest figures in history. I understand if you don’t agree with the derby, but unfortunately there’s no other way to lower the wolf population quickly. You can’t translocate, IDFG won’t allow it. You can’t take them out of the wild and put them in places like “Wolf Haven.” There’s no room for all of them. I mean come on….the goal of the FWS was 10 breeding pairs or roughly 100-150 wolves. What are we at now, 75+ breeding pairs in Central Idaho alone? Good lord people, how many do you want? Do you only care about the wolves because they look like your german shepherd? What about the elk, moose, deer, sheep, goats? Did you forget about them. This tunnel vision thinking has got to stop. You have no clue what the definition of wildlife preservation and conversation is!
I live right in the middle of Montana and it’s predators. By far there is more predation done by poachers and vehicles than wolves or coyotes. Just pick up the paper. In Kalispell alone poachers have gone on a killing spree. Not just 3 or 4 mind you…DOZENS. Educate yourself before you take “pen in hand”.
Try all you want to stop the derbies going forward, we WILL continue to harvest predators until they are at a manageable level. WA state ranchers and farmers have already declared states of emergency in their counties, giving them legal right to shoot on site in the act of depredation, despite their status at the state or federal level. You will lose this fight against sportsman. We’ve done it before and we will do it again…we are doing it again, right now!
If folks are irritated by Luke’s comment, I suggest writing out a check or an on-line donation to the Western Watersheds Project to counter this biologically ignorant nonsense. http://www.westernwatersheds.org/2014/08/om-289/
irritated but not so much at Luke because
when he writes, “You will lose this fight against sportsman. We’ve done it before and we will do it again…we are doing it again, right now!”
he is right. But so are you if irritated then we have to fight back whether by check or action. People that like to kill for fun get away with it because they piggy back their culture of violence and collude with sportsmen and lobbyists like the NRA. Then they are a big unified force that is hard to contend with.
But Luke you are not a “sportsman” you are really a guy who does not take the time to educate yourself about natural systems and the role that predators play in them. You are the guy that is close minded and somehow you are able to ignore the beauty and magnificence of species like wolves, coyotes, fox, and bear that are often the target of “derbies” and you have lost your way and really believe that killing animals in contests is fun or sporting. It’s just not. its creepy and will be illegal. Its just a matter of time
Lost my way? Closed minded? Honey please, I’m extremely open-minded and probably one of the 10% or less of true sportsman out there. I give back 200+ hours every year to conservation and preservation of our ecosystem and fully support FUNCTIONAL programs that are for the BETTERMENT of wildlife. Wolves destroy ecosystems and have to be managed. There is no such thing as a natural ecosystem anymore. Everything is managed by man. The problem is closed-minded people like YOU that look at these predators like they’re your pets or your friend. Well darling, spend a day being stalked in the Salmon Creek Wilderness and I can promise you that your view will change completely. Until then, you, have no right to express your opinion. You’re not a sportsman, you do not provide for yourself and you haven’t the slightest clue what these predators are capable of. Again; they will be managed , with or without your support so I suggest you do the right thing and get on board.
Yikes its amazing you are still around to warn of the impending threat of a carnivore catastrophe….with all the stalking! I’ll keep it in mind from now on.
Nope, not “all the stalking.” One time in Idaho. I’ve hunted in ID, WA, MT and UT for years and have never feared for my life until that day. Until you experience it first hand, it’s really hard for your opinions to have any value. Get out there. You don’t have to hunt, just hike. Head down to Dixie, ID. Spend a weekend in the woods. All of you on here should spend some time around these predators. They’re terrifying and WAY overpopulated. Something’s got to change. Our wildlife population cannot and will not support the wolf numbers we have right now.
Now we know what drives Luke.
Gee, Luke – if they are that terrifying, GO HOME.
Luke, your position of wolves being destructive proves that you are close minded, because you have not caught up with new research showing that predators are vital to healthy ecosystems. This is the exact reason i have become less fond of hunters over the years.
Yeah, make a donation where less than 1% of the proceeds go back to the betterment of fish and wildlife. Genius. #clueless
You’re not a “sportsman” by any definition I’d use if you’re willing to condemn predators out of hand. Your mind is so far from “open” that you’re not even on the continuum. You seem to have no idea what ecology or ecosystem mean, and clearly do not spend time in any professional capacity working in ecology or on ecosystems. You’ve never been stalked by a wolf – c’mon, that’s just nonsense. You have what appears to be a poor working knowledge of predator biology and irrational fear of predators. You’re behaving in a hostile, nasty, condescending, and troll-like manner.
And I hate that someone needs to write this, because you could have entered into some meaningful and useful discussions rather than trolling in utter ignorance.
EVERYONE has the right to express their opinion, including you. It’s covered under Amendment 1 of the Constitution of the United States. I assume you’re familiar with the document?
Want to start again?
Well I don’t agree with him entirely myself. I still think he is pretty good theoretical opposition. I’ve been stalked by wolves. So maybe he has been stalked by wolves. Maybe the wolves weren’t stalking me just following me? Checking me out? You define it.
No idea what he truly meant. I assume that he means a wolf or wolves were stalking him in an attempt to make him the first fatality in the lower 48 since the reintroduction, and consume him. Followed briefly, investigated, checked out carefully, yes, I might believe that.
I’ve not experienced any direct threat from any wolf. Although a couple bow hunters tell me they killed a wolf that was lunging towards them challenging them like a dog protecting property. Other wolves were around stalking observing doing whatever. I’ve had bears wreck my camp. I’ve had wolves go through my camp while I’m there. I’ve had wolves howling around my camp. No big deal. I thought it was funny. Wolves are no more threat than a bear or cougar might be or even a bull elk. Dangerous of course. So what. I’ve had a bull elk darned near do me in once in my life, that was a rush. He was little hot and I was five yards away. And I missed. lol.. Hell my horse stomped me a couple of times as well. Gone down to the ground with a horse twice in the back country. People try and kill themselves at rodeos for crowds viewing pleasure every year. A week ago I tried to hike myself to death,lol.. Things are certainly changed out there and its not all carnivores doing the changing. Other problems are habitat loss within forests and on historical winter ranges from drought and fire. Mismanagement of hunting opportunity which began before 1995. Winter kill. Seems to me those problems themselves warrant carnivore management. I’m going for another cord tomorrow so maybe My chainsaw will get me..
I’ll tell you what; go to youtube, search for wolk stalks and let me know what pops up…then we’ll chat.
You’re right; everyone does have the right to express their opinion and I happily and freely express mine. The only difference is mine are based on real-life experience and factual data provided by biologists that I know personally, shake hands with on a weekly basis and discuss wolf mgmt plans in WA state twice a month, not pro-wolf websites and shitty forums but up by tree-hugging hippies that haven’t the slightest idea what they’re talking about. BTW, if you’re trying to get under my skin with comments like “You’re behaving in a hostile, nasty, condescending, and troll-like manner…,” you’re wasting your time here friend. I don’t respond to prodders and dipshits that waste their time with five dollar words and jabs to make themselves feel better. Sorry, not my cup of tea.
As far as my rights go – well aware. Why don’t you pay a visit to Spokane, WA and I’ll gladly share my 2nd amendment rights with you. Deal? Great.
Luke, since I am privy to the figures for this organization, I can say it is one of the most efficient conservation organizations out there. That is why they can file so many lawsuits on an annual budget of only 800-thousand dollars.
Only 800 grand? Only? Wow…what a waste of time and someone else’s hard earned money. It never gets you guys anywhere and you’ll never get what you want in the end. All you’re doing is slowing down the process and hoping that your pet wolves will decimate the entire big game population in the meantime. It’s a joke and a bad one. This is not a conservation organization, this is highway robbery.
That number really bothers me. $800,000 dollars wasted on litigation does nothing for our environment – at all. Why don’t you put that money into something else that will actually protect our future generations? Wow…just floored. Sad.
You are a troll. So go back under your bridge. Bye Bye!
It’s about time to write another check to WWP. Keep up the good work, Ralph, et al.
Just wanna thank all of u guys for stating the facts about predators . Luke I live in Wyoming and am always told the elk. moose population is down because of the Canadian wolves, so why is there a elk hunt in Teton National Park to reduce the elk population? What up sportman’s? Come on dude live in the year 2014, u may like it
Those responsible were probably practicing up for the predator derby.
Quote from a book I’m reading now that sums up the philosophical change in regard to our wildlife in general and predators in specific.
“- a strange disconnect, considering that traditional hunter-gatherer societies insisted on a deep spiritual bond with the creatures they sought, gave them respectful, meaning-laden names, and generally saw them as equals, if not being with supernatural powers; in the terminology of Austrian theologian Martin Buber, an I-Thou relationship. Mainstream modern sport hunting, as represented in hook-and-bullet television and magazines, insists on a link Buber would have labeled I-it – objectification rather than engagement, pursuing and killing faceless creatures as a given, legal right, for our own entertainment or profit, or just on a whim.”
Yes. Even calling them ‘renewable resources’, which calls to mind a carnival duck shooting gallery, where when one inanimate metal or wooden duck goes down, another springs up in its place. 🙁
This is a comment written by Guy Dicharry, attorney at law. He and his wife Liz work very hard to end wildlife killing contests. Its an excellent comment and I asked Guy for his permission to post here in its entirety. I’m hoping it will provide some good talking points. Thanks Guy for all your commitment to end killing contests.
October 14, 2014
sent by email to: BLM_ID_predatorhuntderby@blm.gov, email@example.com,
United States Department of Interior
Bureau of Land Management, Salmon Field Office
Attn: Liz Townley, Outdoor Recreation Planner
1405 Hollipark Drive
Idaho Falls, ID 83467
Dear Ms. Townley and recipients:
I am providing comments to the EA within the prescribed deadline. Quoted excerpts from the EA are numbered and in bold italics. Comments are under the quoted excerpts from the EA.
1. “The animals targeted for the derby could be harvested legally even if the event was not occurring.” EA, page 13.
Comment: While factually accurate, this statement mischaracterizes the point of conducting an EA. The issue is not whether the target animals can be hunted by individuals outside of the proposed contest. A finding that hunting is legal tells us nothing about the impact of the proposed activity — wildlife killing contest — on BLM resources. If the proposed activity involved an obviously illegal activity (e.g., the contestant who poaches the most elk wins the elk poaching contest), then the illegality of the proposed conduct would lead to a quick denial of the SRP application. Conversely, legality of hunting the targeted species sheds no light on the complex issue of the impact of the IFW contest on BLM resources which includes all of the target species and their habitat. Legality of hunting targeted species is nothing more than a threshold issue that plays no role in the substantive analysis of the proposed activity required under NEPA.
2. “The IDFG does not expect the species to be affected at the population scale.” EA, page 13.
Comment: The EA contains no citation of authority for this opinion by IDFG. The issue of how and when coyote populations respond to different levels of exploitation (removal/killing) is complex and not addressed adequately in the EA. See, comment No. 5, below.
3. “The long-term goal is to reduce predator numbers enough to allow increased game numbers, increased harvest opportunities, and to maintain viable populations of all wildlife, including predators (IDFG, 2012).” EA, page 13.
Comment: In its written, published policies, the IFGD expressly rejected the use of wildlife killing contests as a valid method of wildlife management. Predator populations in Idaho are managed through a number of mechanisms, but the Department is clear that predator killing contests are not a wildlife management method.
“However, the Department will not support any contests or similar activities involving the taking of predators which may portray hunting in an unethical fashion, devalue the predator, and which may be offensive to the general public. The Department opposes use of bounties as a predator control measure.” (emphasis added)”
Last December, the Department received many queries about the Salmon contest, the same event that is the subject of the Notice of Proposed Action. In response to the many letters and emails, the Department issued the following statement and guidance on its position:
“Idaho Fish and Game has not been asked and will not provide any financial support or logistical support for this event.
13 years ago, the Idaho Fish and Game Commission adopted a Predator Management Policy that states ‘Fish and Game will not support any contests or similar activities involving the taking of predators which may portray hunting in an unethical fashion, devalue the predator, and which may be offensive to the general public.’ ” (emphasis added)
The EA refers to general language regarding wildlife management to imply that IDFG endorses wildlife killing contests as a form of wildlife management while ignoring specific statements by IDFG to the contrary. The IDFG has clearly and unambiguously rejected wildlife killing contests as a method of wildlife management, a simple fact that should have been incorporated into the EA but appears to have been deliberately omitted.
4. “A study in Idaho (Hurley, et al., 2011) has tried to remove species like coyotes from an area to increase survivorship of prey species. However, the study concluded that coyote removal had no detectable effect on the population growth rate for mule deer in the study area.” EA, page 13.
Comment: This study found no detectable effect on population growth of mule deer after coyote removal. That finding calls into question the unsupported IDFG opinion that reduction of predator numbers allows increased mule deer numbers and harvest opportunities. According to the Hurley study, predator removal has no effect on mule deer populations. If, as appears to be the case, predator removal cannot be shown to further the goal of increased mule deer numbers, then IDFG’s position supporting predator removal as a method of increasing game numbers lacks a scientific foundation. BLM’s decision on the SRP application should be based on reliable science and not on hunches regarding the complex relationship between predator populations and mule deer populations.
5. “As for the population of coyotes, studies have shown that harvesting 75% of the population annually would not exterminate the population over 50 years, due to increased reproductive rates in areas where coyotes are intensively controlled (Voigt & Berg, 1987). Even under the most severe removal programs, repopulation by coyotes can be expected within months (Beasom, 1974) or 2–3 years (Connolly & Longhurst, 1975) (Connolly, 1978), (1995).” EA, page 13.
Comment: In fact, Connolly and Longhurst showed a 3 – 5 year period to return to pre-removal densities, not a 2 – 3 year recovery as stated in the EA. Most importantly, during that 3 – 5 year period, no coyote removal took place in the study area. “Coyote populations reduced by intensive control [killing coyotes in the study area] returned to pre-control densities within 3 – 5 years after control was terminated.” (emphasis added) (Connolly 1995). Even in the absence of any killing of coyotes, a recovery period of 3 – 5 years was required for the population to return to pre-removal levels in the study area.
The EA also inaccurately states that killing “75% of the population annually would not exterminate the population over 50 years”. In fact, simulated populations declined to zero over the course of 50 years when 75% were killed annually. (Connolly 1995).
The relevant scientific literature supports the “No Action” option on the SRP in this case for a variety of reasons.
• The contest promoter, IFW, wants to hold an annual event for a 5-year period. That schedule of contests, standing alone, would interfere with the 3 – 5 years needed for recovery as observed by Connolly.
• If the SRP is issued to IFW in this case, BLM should anticipate other promoters wanting to join in. It will be difficult to justify refusing to issue SRPs to similarly situated contest promoters. These additional contestants will create more pressure on the population, thereby rendering recovery estimates of 3 – 5 years as too short in duration and extremely unlikely.
• As noted above, no control measures — killing of coyotes — took place in the study area during the recovery period. That is not the case on BLM lands. While coyote populations are pressured even in the absence of contests, that pressure will necessarily increase once SRPs are issued for contests. More contestants trying to win prizes means shoot early and shoot often. Issuing an SRP for this contest — and for the others who will almost certainly follow — means that there will be no meaningful period of recovery in the absence of removal. That is a substantial departure from the experimental design adopted by Connolly and Longhurst.
Connolly and Longhurst collected data in the mid-1970’s. [Connolly did not collect new data for the 1995 paper.] Those data are now approximately 40 years old. BLM must consider the following as having additional impacts on coyote populations:
• widespread proliferation of predator killing contests through the western US
• the invention of the predator hunting industry
• the availability of semi-automatic rifles to the American public
• the widespread use of electronic callers
• significant habitat changes
The populations would have no meaningful recovery period, all the while being subjected to more contestants possessing more efficient methods of killing than were present in the mid-1970’s, the point at which Connolly and Longhurst collected data. The issue of how and when coyote populations respond to different levels of exploitation (removal/killing) is complex and has not been addressed in the EA. See, e.g., “Carnivore in Ecosystems: The Yellowstone Experience”, Clark, Curlee, Minta, Kareiva, Eds., 1999 Yale University Press. Chapter Six, “Coyotes and Canid Coexistence in Yellowstone”, Robert Crabtree and Jennifer Sheldon.
On the issue of how and over what period of time coyote populations respond to different levels of exploitation, the few studies cited in the EA do not support the propositions for which they are cited.
6. “Some user-created conflicts could occur if competitors and others are concentrated in one area. However, this is unlikely as hunting is generally a dispersed activity because hunters desire to be isolated in hopes of viewing more game.” EA, at page 18.
Comment: The EA assumes, incorrectly, that there will be uniform dispersal of contestants over all lands managed by BLM. The assumption does not take into account the following:
• The promoter (IFW) stated a preference for BLM lands for the contest. The promoter had access to 5.8 million acres of Forest Service lands for the 2013 contest, yet insisted on applying for the SRP to add BLM lands to the millions of acres already available. If BLM lands are made available, it is likely that they will be seen as preferable to other public lands already open to contestants. That situation will lead to a concentration of contestants on BLM lands.
• Coyote contestants prefer open areas which tend to be lower elevation and higher use by others in the winter months. Past winners of other wildlife killing contests advise changing stands every 12 to 15 minutes to increase the likelihood of winning. Changing stands frequently also increases the likelihood of user-created conflicts.
7. “In terms of effects to predators and scavengers at a population scale, target species would not be affected by the proposed hunt. The coyote population, for example, would be expected to rebound quickly after each event, as has been observed by IDFG in previous coyote removal studies.” EA, at page 19.
Comment: The EA is silent as to which “coyote removal studies” this inaccurate conclusion is based upon. Coyote removal studies do not support the expectation that the coyote population “would be expected to rebound quickly after each event”. The issue of how and when coyote populations respond to different levels of exploitation (removal/killing) is a complex one. It has not been addressed in the EA in a manner which would allow BLM to draw any science-based conclusions about the effect that this wildlife killing contest will have on coyote populations.
See, comments to item No. 5, above.
8. “Hunting derbies are regulated through an SRP because they are competitive events. The BLM may allow hunting derbies within WSAs if they are temporary (so they do not create an expectation that they will continue after designation) and do not cause physical alterations.” EA, at page 20.
Comment: If the SRP is issued in this case, it will necessarily open to door to other promoters who will want to exploit BLM resources for their own commercial, competitive events. The BLM should reasonably expect other promoters of wildlife killing contests to file SRP applications for similar events. What may appear to be “temporary” with one applicant will become a series of wildlife killing contests using the same areas over and over.
9. “However, as explained in more detail below, most of the use associated with this event would not occur within a WSA, and it is unlikely that many of the WSAs would see any use as a result of this event.” EA, at page 20.
Comment: If this statement is true, then there is no reason to allow the competitive event on any WSAs. The IFW contest should not be allowed on the WSA based on non-impairment criteria alone. Those criteria are intended to preserve wilderness characteristics pending approval of designated wilderness status. One of those wilderness characteristics is spelled out clearly: competitive events are not allowed in designated wilderness. In addition, the EA emphasizes the unlikelihood of any contestants using the WSAs. Given two compelling reasons to exclude WSAs from use in the contest, a decision that would allow contestants to use them is arbitrary.
10. “The use of WSAs for the proposed competitive hunting event meets the non-impairment standard because the action is temporary, short term, and would not create any surface disturbance.” EA, at page 22.
Comment: The use of WSAs for the proposed wildlife killing contest does not meet the non-impairment standard because the activity is neither temporary nor short term as those terms are defined in BLM Manual 6330. The prohibition on competitive events in wilderness areas is well-established and not in dispute. According to BLM Manual 6330, a use that is incompatible with a wilderness designation violates the non-impairment standard, even in the absence of new surface disturbance.
“It is the BLM’s policy not to establish new discretionary uses in WSAs that would impair the suitability of such areas for wilderness designation (see section 1.6.C). For example, identifying a mountain biking route on an existing primitive route may not create new surface disturbance or permanent facilities, but the use of the route may preclude potential designation the area as wilderness and would therefore violate the non-impairment standard.”
Source: BLM Manual 6330 §1.6(B)(5).
Granting an SRP for the IFW contest will create a demand for more contests using the WSAs. Merely creating a demand for more wildlife killing contests on WSAs would be incompatible with wilderness management for two reasons: (1) competitive events are not allowed on wilderness areas; and (2) multiple contests are not temporary within the meaning of Manual 6330. The standard is whether the use (IFW contest) will create a demand for uses (more contests) incompatible with wilderness management.
“A chronic, repeated short-term use does not meet this definition of “temporary.” Uses, activities, or facilities that create a demand for uses that would be incompatible with wilderness management also do not meet the definition of temporary.” (emphasis added)
Source: BLM Manual 6330 §1.6(C)(1)(a).
Based on the plain language in BLM Manual 6330, all of Idaho’s WSAs should be off limits to competitive events such as the IFW contest.
The proposed activity confers no legitimate benefit to the public interest in public lands. This commercial, competitive event is inappropriate for BLM lands. The EA failed to demonstrate a sufficient scientific basis for granting the SRP. Equally compelling is the degree to which the public has objected to this particular use of public lands. The application for an SRP by Idaho for Wildlife should be denied and the BLM should choose the “No Action” alternative.
Connolly, Guy E., “THE EFFECTS OF CONTROL ON COYOTE POPULATIONS: ANOTHER LOOK” (1995). Symposium
Proceedings—Coyotes in the Southwest: A Compendium of Our Knowledge (1995). Paper 36.
WM, JB, Immer, Ralph and others was hoping to see your thoughts on Guy’s comment. Rork after your comment about opposing killing contests as hypocritical am also very interested in hearing from you on this. I found this comment to be extremely well researched, reasoned and persuasive despite my prejudice against coyote and other wildlife killing contests.
Guy again thank you for a well researched and to the point analysis of the BLM EA and your comment.
Thanks Guy and thanks Louise, for posting it, and just so people know what the “playing/killing” field looks like, an article on the subject:
“Though I own enough predator calls to outfit every kid in the congregation with one during the local church dinner party”
Got to love that little reference to religion. It somehow makes it all right to wantonly kill if you’re doing your part to hold back the tide of predation.
Thank you for sharing, Nancy. The author of that article certainly shows his arrogance. One of the most disgusting human traits, IMO. That is okay. The opposition is growing. I won’t state my plans in public, but as I wind down my M.S. work and finish (in mid-life, LOL!) I will pick up the pace in other areas.
The wolf may be the most charismatic, but the coyote is America’s song dog. Who knows? In the future, we may find our coyotes wrapped in a flag flaunting a cross.
Most of the writers in petersens hunting are extremely backwards when it comes to predators.
Thanks Louise for posting and thank you Guy for a great response to the BLM EA. With regard to the BLM contention in the EA that user conflicts would be unlikely, in my comments I asked the question of how safe it would be to walk your dog on the BLM land during the contest. I suspect not many of the BLM officials would be willing to take their dogs out for a run during the contest. In fact I feel it would be unsafe to walk anywhere in the area during the contest – with or without a dog. The fact that the killers are dispersed and could be anywhere makes it even more disturbing.
The area proposed is huge and the number of contestants will be minimal 200 to 300 at the most. The chance of getting shot is less than a Canadian wolf pack attacking you. Enjoy the dog walk.
Elk the number of hunting accidents in the US each year is portably higher than you think. Guy has written a very precise analysis of why the BLM should not issue a permit. The dog issue aside, when 50% of species are lost in a 40 year time period should a burgeoning emerging cultural tradition that targets wild animals in a killing contest be anything that anyone should subscribe to for any reason. I think not
Elk, are you sure you have checked statistics on hunting accidents compared to wolf attacks….Ever? No person has been injured or killed by a wolf in the US northern rockies modern times. Meanwhile, there are hundreds of hunting accidents every year across the US….
WHAT DID I WRITE, PLEASE READ IT.
“The area proposed is huge and the number of contestants will be minimal 200 to 300 at the most. The chance of getting shot is less than a Canadian wolf pack attacking you. Enjoy the dog walk.”
What I said was that during this “event” which is 3 days long and should have no more than 200 to 300 participates that the chances of getting shot should be less that getting bit by a wolf. I do not think that anyone is going to get shot or bite by a wolf.
What did Louise Kane say: “Elk the number of hunting accidents in the US each year is portably higher than you think” This is not for the US each year, this is for a three day event.
What did Amre say: “Meanwhile, there are hundreds of hunting accidents every year across the US….” This is not every year across the US.
What did Rich say: “Far more people are shot by hunters every year than are bit by wolves. I don’t recall anyone being bit by a wolf in Idaho in the last 20 years. Unfortunately several people have been shot and injured or killed by hunters in that time period and even more dogs were used for target practice.”
This is for a three day event not for the last 20 years.
Elk: This Idaho predator killing contest is for 3 days… for the next FIVE YEARS.
It does not matter no one is going to get shot. Predator hunters use top of the line rifle scopes and optics. A coyotes body from the brisket to the top of the spine is between 5 and to 6 inches. The shooters is going to have to take careful aim, calculate the hold over if the distance is in access of 250 yards. The shooter is goig to pay attention and no one is going to get shot or bite by a wolf.
I do not know the season structure in Idaho but why worry about this three day predator contest when all hunting seasons last three to four months. Montana’s hunting season starts September 1 and ends January 1. I would worry more about the general season than a 3 period.
In think that the most dangerous thing during season is driving to the field. What scares the shit out of me is pulling a horse trailer in the mountains on ice.
“In think that the most dangerous thing during season is driving to the field”
And in case some forget, it use to take days and days just to get to the field on horseback. How comfortable it must be now, pulling a horse trailer, even in the mountains on ice 🙂
Still got that wonderfully expressive mule, Elk?
Elk statistics aside the danger of these contests is not so much about the chances of getting shot its the mindset behind them. Its just bad policy that killing contests are legal or permitted anywhere but especially on public land especially when 50,000 plus people commented against and 10 commented for.
number of hunting accidents in US and Canada 1000 per year
I bet thats less than number of livestock killed by wolves in the western states. anyone know
Louise, this is the data from the 2013 annual report on wolves in the NRM DPS
confirmed depredations by wolves in the NRM DPS
You were correct about there being more hunting accidents than livestock depredations by wolves in the west.
Thanks Amre what report was it
Louise, it was FWS’s 2013 annual report on wolves in the Northern rocky mountains of Montana, Idaho, Wyoming, Washington, and Oregon.
Your statement that:
“The chance of getting shot is less than a Canadian wolf pack attacking you.”
is clearly false.
Far more people are shot by hunters every year than are bit by wolves. I don’t recall anyone being bit by a wolf in Idaho in the last 20 years. Unfortunately several people have been shot and injured or killed by hunters in that time period and even more dogs were used for target practice. You may want to run the numbers before making a statement like that. I think I’ll keep my dog out of range during the war – oops – killing contest.
In fairness to “Elk” there are probably thousands more hunters than there are wolves…
That said, even though wolves are large capable predators, there has been no case of wolf attacks since reintroduction in the lower 48. A wolf with structural malformations in its jaw dragged a teenager from his sleeping bag in MN a year or two back. Yeah, it can happen.
But ask that guy who lost his malamute to a wolf hunter with a case of trigger itch what he thinks.
I sent my comments to the BLM one week ago and they had received over 27,000 e-mails to date. As a former BLM employee, my bet is they will deny the SRP for a variety of reasons (mainly due to social and economical reasons) and that it can be conducted on private land instead of public lands.
Just talked to an out-of-state deer hunter (he couldn’t afford an elk tag) who didn’t get a buck or see many deer, but he saw numerous groups of 150-plus elk in the Salmon/Lemhi area. There would probably be more moose here if they didn’t keep getting killed by vehicles or murdered by illegal road hunters.
When a congressman asks for an extension to the comment period to a killing contest EA, I think the “heat just got hotter” for the BLM Salmon District office. There is sufficient private land in the project area to deny this event from occuring on Americas public lands.
Haven’t human caused enough damage. It’s been proven that these horses are vital to the land by scientist. All i see is people trying to make another quick buck no matter the consequences. BLM is just another part of agriculture playing dirty for nothing but greed.Watch and listen to the whistle blowers here…http://www.youtube.com/watch?v=qSV8pRLkdKI
There is only one reason what so ever for having a coyote and wolf derby which is for commercial gain for hunting outfitters. Holding the derby on public lands will not lower winter kill. Yes wolves may cause elk, deer, moose &c. be more wary and less apt to advertising their whereabouts even during rutting season. Hunters that have minimal hunting and tracking skills claim that wolves have killed them all. When in fact is they are hunting on the edge of clearings where they have seen elk in the past taking the easiest and laziest means of hunting. These hunters now need to adjust their hunting habits. Hunters are going have to do preseason scouting setting trail cams in areas just off the trails where elk, deer, &c. travel to and from feeding and watering holes. These animals will not be on the edges of clearings during daylight hours they will be in areas that there is heaver cover. If there is in fact a depressed population of elk, deer, &c. is the case. It can be attributed to hard and long winters and decades of over hunting along with mismanagement of game, and hunting licenses. All in all it comes down incompetent hunters and their refusal to change their hunting habits.
There is one other reason for coyote, and wolf derby and that it makes these incompetent hunters both male and female feel as if they can now put on their big boy/girl pants/panties. The killing of a predator for some reason makes them feel macho or some dumb ass thing like that. When better that 75% of the States Population are against this type of contest. And farmers are complaining about elk, and deer are eating their crops there is something wrong with the States FWS Dept. As previously stated mismanagement of the Wolf and Coyote Population. Maybe relocation of these predatory animals is in order.
I am going to look into what compaines are sponsering this so called derby, u need to boycott these companies and make it known that these companies are involved in this, hit them in the pocket, money always talks
Here’s a novel thought. Why don’t we let each states DFW make the hunting season for these animals….Oh that’s right, they already do…
Why is it there are so many of you for the predators and not the rest of the animals in the forest? Is every other animal just a token meal for the predator? I don’t think so…..
What the hell, they have fishing derbies, are they next on your list of don’t do’s.?
We’ve said over and over that we are for all of the animals, not just predators. Predators are persecuted more than other animals. Nobody wants to accept that as an answer, so we’ll keep repeating it.
Why do some of you persist in wanting to change the laws of nature?
Fishing derbies aren’t great, but there is catch and release, and they are eaten as food also, not destroyed because of false human perceptions. Traditional hunting is acceptable; but predator derbies are exercises in human primitiveness, and hunting out of your vehicle and poaching are for lazy slobs. Okay?
Idaho Department of Fish and Game requires permits for fishing derbies.
Thanks Ken Cole: And, I’ll replay your important message on Idaho predator killing derbies:
“The Idaho Department of Fish and Game Commission adopted a Predator Management Policy in 2000 that states: Fish and Game will not support any contests or similar activities involving the taking of predators which may portray hunting in an unethical fashion, devalue the predator, and which may be offensive to the general public.”
As you say, “Clearly, these contests are offensive to the general public, they devalue predators, and portray hunting in an unethical fashion.”
Peter De Fazio’s comment to BLM, as posted by Predator Defense to its members
Bravo and thank you
40000 (!) oppose that massacre planned by those sporty sportsmen.