2885 S Gilpin St

Denver, CO 80210

303-759-4056

January 11, 2008

Office of Pesticide Programs, Regulatory Public Docket 7502P

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, D.C. 20460-0001

Re: Docket Number EPA-HQ-OPP-2007-0944

To Whom It May Concern:

I urge you to ban scented dispensers of poisons (such as M44's),
poison-filled stock collars and any related devices, *regardless of the
specific poison they contain.* Please also ban both sodium fluoroacetate
(Compound 1080) and sodium cyanide. In my opinion, these bans are
required to protect the lives of humans, pets and large numbers of
native wild animals.

Never before have wild and distant places been so available to large
numbers of people, people with little or no awareness of the risks to
them or their pets from poisons intended predators. Humans, often
accompanied by their dogs, roam ever further afield on bicycles, ATVs
and other off road vehicles. The results of this new closeness to
predator poisons is about 100 pet dog deaths documented annually by the
USDA Wildlife Services. It's my impression that the few human deaths
associated with predator poisoning have involved those who intended to
use the poisons rather than the general public. Given children's
curiosity, however, this could change.

For each of the last four years, USDA Wildlife Services has documented
ten- to fifteen- thousand wild native animals killed by M-44s armed with
sodium cyanide. The vast majority of these wild animals were "collateral
damage." They died because they were scavengers, predators, or simply
curious animals attracted to an unfamiliar odor or object, not because
they as individuals had attacked stock. The innocent wild victims of
M44s include badgers, black bears, bobcats, bald eagles, gray, red,
swift and kit foxes, opossums, marmots, raccoons, ravens, ringtails,
skunks and even Endangered Species like condors and wolves. It is likely
the majority of coyotes killed also had not preyed on livestock.

There also have been many undocumented wildlife deaths attributable to
these devices and poisons. Because birds may fly from the scene of their
poisoning in the seconds before becoming acutely ill, their deaths from
M44s may be particularly underreported. And there are additional
undocumented wildlife deaths from Compound 1080. Stock collars that
become entangled in barbed wire, cactus or bushes may come off and
eventually leak or be breached by wildlife. And collars on animal that
died from causes other than predation may contributed similarly to
deaths of non-stock-killing wildlife. Because death from Compound 1080
takes 3 to 15 agony-filled hours, the poisoned wild animal may die a
large distance from the poison source and therefore remain uncounted
even when the source is located.

There are many threats to a rancher's stock, such as extreme cold, deep
snows, drought, birthing, and theft. Documented predation accounts for a
relatively small portion of total stock losses. Use of guard llamas and
guard dogs, and steps such as keeping birthing animals in shelters or
specially fenced pens may be useful to protect stock. If available
methods of protecting stock are inadequate, then scientifically designed
and tested methods of stock protection that do not threaten wildlife and
the public must be developed and made available to ranchers.

We are in a period when increasing human population and greater
affluence combine with changing weather patterns to threaten mass
extinctions of wildlife species. Allowing anyone to use stock protection
methods that indisciminately kill wildlife is particularly reprehensible
in this time and situation.

Please protect humans, pets and wildlife. Ban Compound 1080, sodium
cyanide, M44s and stock collars, as well as any future use of similar
devices or poisons.

Thank you for this opportunity to offer input.

Sincerely,

(Signed)

Nancy Stocker