-0 

## -. UEliTE3 STATES €ti'/i?O!iPii#TAL PROTECTIOH ih=.\lCy 3EFlzRE -YE J,~)iI~ISP~JTC?
In 

### the /4atczr of ,) Noticc 

### of Hearing 

### on the 

### FIFFW 9ocket No. 502 Applications t3 Use Sodium 

### iluoroace~ate (Covpound 10aO) ) \ To Control Predators 

# i

, Initial Oecisicn 

# -
This is a proceeding under Seciion 5(d) of rhe Federal Iasec:icide,

. , Fungicide and Rodenticide Act, as amended (7

### U.S.C. 136(d)) 

### , to recons7cer 

### - rne Administr~tor's order (P4 72-2, Harch 9, 1972, 37 

### F?, 5713, "arch 18, 1972) suspending and cancelling ihe registrations of sodium fluaroacezare (Cs~pound

### 1086) for the control of pr2dacors

. The cr-oceodina 4 was triggered by appiicacions 

### i~r registration or erner2eccy sxempcicn dncer Secs. 3 and 18 ofthe Act, filed by the iish and 'riildlif. Ser.~ice of ih2 U.S. Oepartinent 

### of Interior, and ihe States of Xoneana, South Oakora and

-1 2yornming. ine Administrator's Setowinaxion 

### to hold i nearing sn che applications and the issues to be csnsiderzd (Atxacbnenc A) 

### srs set ior~h in ;he Xotice of Hearing, 

### da~ei Uecember 

## :, i9E: (16 F?, lo. 232, December 7, 1981

### , at 59,622, 

### et s2q.)



### . The issues 

### to be addressed aer. expanded 

### to include smear posts 

### as a delivery mechanism by notice, dace:! March 3, 1982 

### (47 FR Eio. 47, Piarch 10, 1982, 

### at 10,258).This ~race~dins ijeing concucwd under 32 Zules 9f ?mctic2

8 

### - joverning hearin~s under ~n2 r2cer:i 

### , Inszczicide, F~n~ic: ie 3r,d ?>acen?'c:22

??* Act (40 CF2 Part io~) and in ?articular Sujparz D ;?,ereof. In acc~rdanc2 with hragraph 164.131(a)

### , tne Adninisrrator rcvievded 

### fne appifcacions for registra~ion 07 Compound 1080 and detnined thsi r?consideration of 3 the suspension and cancellation order kas warranted. The cited secticn provides in par:: "The Administrator shall de12rnine thac such reconsideration is [warrantedWhen he finds chat: (i) the applicanc has presmted sunstancia1 new evib2ncc 1,qhich aay ~at~t-i a:

### iy effect zhe ?rior cancellation or 3us;ension or&r and which was not available to th? Adzinisfrator,at the tire he nade his final cancellatioj.

### or suspensian detminacion and (2) such evidencs could not, chrough the zxercise of due diligence, have been discavered by 

### rhe partiss ta tne canc2llation or susgension proceeding prior TO che issuance of the final order." Paragraph 164.132(a) of tne Subpar: 

### O rules orovides that ihe burden sf proof in the hearing shall be 

### on the a~plicant or applicants who shall proceed first. This section further provides: "The issues in the hearing shall be whether: (1) substzntial new evidence exists and (2) such substantial new evidence requires reversal or modification of existing canceila~ion 

### or suspension order. The deternination of these issues shall be made taking into account the human and environmental risks found by 

### the Administrator in his,canceiiation and suspension determination and the accurnu?ativeeffect of all past and present uses, including the requested use, and uses which may reasonably be anticipated to occur inthe future as a result of grancing 

### the requested reversal or modification."
The ALJ ruled that, although the initial determination under Paragraph 154.131(a)

### as to whether the evidence warrants reccnsideraiion- 

### of the sus9ensi;n 2nd czncellation order must b$ 5ased on .vid?nc? not .yai!?h?,l stthe tim? of the scs~znsion arc! c~nce:i~ci~n xder 3f 7272, <he decision as 

### to~hether the zvic!?nce rquir-54 rev2rsal of ch? prior cancellation and sils~ension order would be xade on the entire rzcord. This ruling was based in part on 

### the Administrator's decision conc2rning Applications to 4egister Sodium Cyanide for Us2 in the M-44 Device to 

### Control Predators (FIFFZA Docket )lo. 382, September lo', 1975)

### , whersi

### n

, the Admiqistrator ruled that avidence should 

### not and c3u;d not be ignored 

### simply becaus? itwas not new since th? 1972 

### order, and in par;, Jn rhe factthat, a1though the vaiidity 

### of the 1972 order is 

### not ac issue, such order is nevertheless being reconsidered. The Acministra,tordetemined that all issues bearing 

### on the 1972 order would be adjudicatsd herein, and the 

### ?revisions of 40 CF4 164.131(a) and 164.132(~), quot2d supr3, 

### mus-i be read and interpretea in the i i,grl-,of xhe issues the Aaminlistrator 1 has noticed for determination. issuesl such 3s 

### che 2ffecCveness sf Compound 

### 1080 large baits in reducing preda3io nand whez,ler the rrlsks 2-; primary and secondary poisoning were overest-ii-i~ated in 1972 

### car! hardly be addressed without considering, inter alia, 2videncc of the 2xtent 

### of injury 

### to non-target l~ildlife prior 

### to 1972. 

### In view of tne conciusions herein, howewr, no par'. 

### of 

### this decision 

### is dependent 

### upon the validity of 

### the 

### ALJ's ruling in this respect. No r2gistrant 

### or agrieved person filed timely objectjons 

### to the 1972 suspension and cancellation order and no hearing was held thereon. I. 

### Active parties throughout this proceeding 

### are the State of Nyorning, 

### the Departments 

### of Agriculture 

### of the 

### States of Colorado, ?issouri and

## - iirecon, ;he ',ies; '!i rginia Carmisiioner 

### si Agnculcsre, cne Zuni i~joe,

. . 

### ,,= or similar ;rszniza~~ans ;he Natiocal Cat:? sizn's >,ssoc;a~;on arcdafii1ia-Q- 

### --., thereto in 36 s~ates, the National %oolgrowersAs;ocia:ion and 3~~11iat2s


### or organizations similar thereto in 13 stztes, the Public Lznds Council and the 

### New Mexico Public Lands Council, vzrious individuals including 1 

### 11 Dr. ',daltersoward- of the Universi~y sfCalifornia, the forecoing par-cies referred 

### to hersinafter 

### as dyoming

### , et a1


### . ; ;he States of Montana 2nd South Dakota; the Fish and :Ji!dlife Servic?; Rznchers Supply, Inc. and The Toxi-Collar Company; Cr. Clair E. Tsrri?1 ; hlerican Farm 3ureau 

# - Federation, ~nd Fam 3ureaus in che S~a~es of Hontana, Yew Nexico, iexas, Utah and Wyorning, hkraina~ter Ai3F; ~iati onai Animal Damage Control


## - Assaciation; Campbell Caunty Predatory issociatian; ;exai Cepartxenc ?f Agricuitur:!; ilew b\e;iico Depart~ient of A~ri culture; Oefenders of 'ii1dliie

### , ?lacionall IAucukon Soci

### ery

### , The Humane Society of the Unit-d Stzres

### , The Arnerican Humane J~scci acion, Animal Protection Instituze oiheri ca

### , Nationa'l Parks and 

### Conservation Association, The Animal We1fare 

### !ns;i tute,

-7 The Fund for Animals, )iatural Resources Defense Counci

### I, I ne Sierra Club, Yational Vildlife Corimittee, Friends of :he Earth and Environmental Defense Fund, hereinaf

### tor referred io 

### as Deienders of 'Ni'I dliie

### , et 31

## . or Defenders; National Ni ldlife Federation, hereinafter NNF; friends of



### I/ Dr. Howard, a witness for Wyoming, et a1

## . in this proceeding, filed-an application, dated December 17, 1981, for an experimental us2 permit involving Compound 1080 in a Bait Delivery Unit (BOU) to control depredating coyotes.% 5 Ir.imalz, Inc.; the United St3t.s cap art sen^ oilsriculture 2nd the

17 1 Ll 

## - nvircnnental Pra~ection Agency. Hearings oii this 

### mattor comenc~d in Wasning~on,

### O.C. on narcn 35,



### - 1982 and were subsequently held in San kngelo, lexas and Denver, Cclorzdo, 3/ 

### - concluding in Washington, O.C. 

### on August 

### 6, 1982. Based 

### on the entire record, including the proposed findings and conclusions and briefs subrnirted by the parties, I find that che follcwing 4/ 

## - facts are established:

Fi ndinas of Fact

8

## -

Issue l(a) (Attachment A) 1. Although dam on sneep losses to predaticn prior ts 1972 

### are fragmentary and inccrnplete, the most reasonable conclusion is

2 In addition 

### to briefs filed by active parties, amicus briefs 

### - vere ii led by the intematicnal Asiociai<on of Fish and Wi id1ife Aaencies, an inactive party, and by the Ohio Ceparmenx of Agriculture and the California Deparwent of Food and Agriculture. 

### An amicus brief was also received from The Resources Agency of California, which is 

### not 

### a parry to this proceeding.

.The Rules of Practice (?O 

### CF? 164.31

### (4)) cemi

### t persons, who are 

### not parties, 

### to fileamicus briefs by 

### leave of the ALJ. Although the briei 

### of The Resources Agency was not preceded or accompanied by an appropriate motion, the briei is accapted. Such 

### a bridf may noc, of course, b2 used to introduce evidence into the record and facts alieged in the brief will be disregarded unless supported by the record. 3/ Although the Plotice of Hearing specified that the hearing be conclcdded within 60 days, the parties found this schedule impossible to meet and the deadline for completion of the hearing was subsequently extended by 

### the Adminisrrator 

### to August 6, 1952. 4/ Proposed findings not adopted are either rejected 

### or considered unnecessary 

### to the decision. Surmary and,,detai1 findings (Attachment 9) 

### are to be read together.;-,hatsilch 108525 ~2r3 OR <lie 3verage :./ithin the ran~e ;f ,3.9 perc2nx t3 7.32ercsnt. 2. ?iurrerous s",ildi?s and surveys have Sean csnduc"cd 

### on sheep and lamb losses to predators 

### sine? 197'. The most compr2hensive of these


### was the 7975 mail survey conductsd by the Statistical Reporting Service of the U.S. Department ofA5riculture, hereinafter 

### &a, eta1


### .,

. T- which gathered data 

### on losses experienced by shew producers in 12 westsrn szates in 1974 and wnich concluded, in~r alia, that average losses t2 coyotzs inthat year were 8 percent cf lanbs and 2.5 percent of sheep. Reported losses to other predators were 3.3 percent of lambs and-0'.9 7ercent of sheep.

. 3. The Gee, 

### et a1


### . resuits have henquestioned for ;he reason, among others, 

### that fieid 

### orbiological studies in Kansas, Idaho, 9tah and Wyoming have result2u in findings of predatzr 1asses of sheep and lambs substantially less than report2d by Gee, et al. for thos? states. Sioloqical studies are very expensive and c3n only cover a



### . . 1imited area or number of flocks. Accordingly, it 7s concluded that the results of sucn studies cannot properly be extrapolated to larger areas, greater numbers of flocks, 

### or to entire stat2s. The data from these studies is inadequate to reach any statistical conclusions and the most. that can be said is that the data provide


### an indication of loss trends. Iloreover, despite extensive searches,
some animals are simply missing and the cause of death or loss cannot -, be determined. Tastimony from ranchers is to the effect that 

### for every lamb ki1led by predators, which islocated, there rn2y he a?many a5 two 

### or three whose remains are never found.

### 4. Lamb 

### Izsszs r2p0r224 k;/ Sae, zt 21. incl;~de 7as55s incurr2d SeScr2


### as qxeil 

### as 

### after dockins. 

### 32causa rany rancners naks no aetznpx to obtain an 

### accurate counx of iamb numbers until docking ("is is alnost always true in range iambing situazicns), producer estimatss of losses 

### to predators prior to docking mustbe viewed i~ri th some caution. !*areover, the record supports 

### the cbnc1usion that few ranchers maintain complete and accurate records sn the causes af a!: 1oss2s

## . 5. Much time and attention ai the hearing was del~ocedco the problzn of non-response bias in conducting mail surveys, xnat is, 

### ranchers suffering the highestpredation losses or nost cgncerneci about przdation would be most likely

### to r3spond co 

### the ques~ionnaire, while those suffering 1izt-lie or no predation aight fail to 3ns~r the quest-ic~nai re. The Sta~i 

### s-ci cal Rzporting S~r-ii 

### ce of :he USDA has been conducting ~ai 

### I surveys for inany years, hcwever, and must be re~arded as expert in the conduct of such surveys. Yoreover, the telephone and personal interview follow-up conducted with 

### a sample ofnon-respondents, greatly redued, if it did not eliminaes entirely, non-respons? bias 2nd any contention that thos2 respcnding 

### to the 

### Gee, et al. survey were not representative 

### of all sheep producers in 

### the states surveyed is rejected. 

### The questicnnaire 

### was constructed in sach a 

### manner as to de-emphasize predation losses (producers being 

### asked 

### to state total losses first) and thus minimize prejudice.the ground that th? survey (tias inszitut2d 5; 3 res~i:3f Csnsressicnai action sponscred by rspr?sentatives of ~est~r~ statzs and that its purposs, that is, 

### to obtain data supporting reversal of the decision suspending and cancelling registrations of 1080 for grgdator control , Z was we11 

### known. The resulting pub1ici ty and the ehocional climaie surrounding the issue of prgdator control arz alizged to qave resulftd

-r l in exaggerated claims of predation ioss2s. ine evid?nce, kowev2r, does not establish thaz the purpose of ihe Gee survey was ca ab~ain reregis~ration of 1080. Even if this was,the puroose or' :he survey, there is no evidence-that this a1leged purpose xas 

### kncem ta produc2rs ' or pub1icized outside of ',{ashi

### ngxon. 7. Enphasis has been ??acedon rne diff'c~l~ies enc~~nwred by ?rgcucers in accurately detzmining the causes ~i deaths 

### o? sheep and iambs. Xhile itis true, for example, thac most ranchers would have great difficulty in distinguishing deaths caused by disease from tho82 causzd by poisonous plants, experienced ranchers have little or no difficulty indetermining predator Ioss2s, if the rerains are found within 

### a reasonable time after the kill. Teeth or fang marks, indications of !z / J1 

## - flowing blood, bits of wool and evidence of 

### a struggle are indices of



### 5/ it

### is recognized that suffocation is the nornal cause of death resulting from coyotes biting 

### the necks or throats of shee? and goats and that accordingly, blood flow may not be extensive.?rodatisn 

### >/el 1 4ncwn i3 enchers. In the qeatra;ori:y of ins;znces 

### here i:ds

### cesn POS~~ jiQ 53 veri

### iy ~rzda~i~n isiies 

### as recorxed by ranchers, i: has Seen cetomined thac tha cause of loss ;qas accuratzly reported. 

### The assertion is mad2 that 

### a sheep 

### or lamb dying of other causes might be scaven~ed and thus incorrectly identified as 

### a predator loss. Xhile this could happen if, for example an eagle 

### or oiher carrion eaiing predator scaveng2d a carcass, it isunlikely intho casa ofcoyoses because cseth 

### zarks in the throat, characteristic 3i

### a coycte ki?1, 1~0~13 be nisslng Noreover, such scar~nging rtould be mcrs ii kely to occur in che winter or colder months bec~use nost ,?recators prefar fresh meai in the sumer. Itiiclear thac 

### iehignes: predrijnn losses io lmbs
occur in rhe sumer. Rancners conscientious~y and in good faich sirive 4I I, repor1 their IOSS~S, i

ncluding 

### 1osses ?redatars. However, oec714-a ,A

4

A \- most ranchers do 

### not maintain accurate records 

### oithe cause 

### of losses, their reports of predaticn 1

### orses nay be unintentiona:ly inflac-d due 

### to faulty memory or "telescoping," incorrectly a~tribucing a loss 

### or losses 

### to one period of time, which, in fact occarrcd In another period. This would seem 

### to be especially true of surveys asking for data on losses for several previous years or for a fiscal year. A fiscal year may bear 

### no relationship 

### to the rancher's production cycle, 

### thus increasing the difficulty of accurately attributing 

### losses to the period when the 

### loss occurred.sheep and lambs lost 

### to ,/ariouscauszs. keindic5~2d th2c his report ~rovided reiiab12 indications of geographical areas and types of operations having the most predation and that the total number of producsrs affzcted was probably quite realistic, b~ause , most,

- 1 I groducers wer2 alttarz of whether coyot~s werz pr2ying 

### on their herds. Gee, 2tal. stated, however, that numbers of sheep and lambs lost to coyctes and numbers of procuc2rs with diffsrent levels ci loss 

### must be considered mor2 caut'ously becaus2 the 

### besree of 9roducer judgment ishigher. 

### - 13. Under a71 che circumstanc~s, the aost serious obstacle ca acc2ptizg The 

### Gee, 2; a1


## . r2sults is the high level of iamb losses actribux-: 2 lamb 

### losses1 co pr2dation- For exanplz, in ?xczss of $5 percznz of ' I 

### to all czuses inlevada were attributd 

### to predation, apprgximat2iy 59 percent in Colorado, approximat2ly 

### 54 percen in Utah 2nd approxirnaceiy 56 percgnt in'Ayorning. Because these losszs include pre-docking losses and substantial numbers of lamb dea~hs during 

### that period
are au2 

### to lambing complications, weather, disease, malnutrition, etc., these high reported predation losses are difficult 

### to accept. Moreover, Gee, etal. state that while most of the large-scale operators reported losses from less than 5 percent 

### tomore than 20 percznt, many sna11-scale producers had no predation problems at

.-. all, and that 5,000 or about one-tenth of the west's sheep ranchers,

.I-, rspor~od i~si2~ exceeciln~ 

### 10 7erz2nt cf 

### Izrnzs xrn. ~i ;i cl?a~



### -- ma: hi:n prsda;;~n s zre SL-rerea

### 5y 3 ?:nor!ry cf ir~~~>~s/~. 11

## . Combined sheep 216 1ai:b 1osies is a11 cizses in 15 :.ies'.?r-~;:a:es have remained stable during rne 7eriod 1960-81, constiiur1,n3

### 8.9 percent of the January 

### 1 inventory plus lamb crop duriig the years 1960 to and including 1971 and 9.0 percenr from the period 1972 

### to and including -1,981. if lamb losses are separated from 

### sheep :csies, sheep losses 

### ts a11 causes jn 15western jtaces 

### have declined from
an average of 7.9 percenc during the period 

### 1560-71 to an average of 6.9 percent during the period 1972 to and including 1981


### . The rec5rd will not suppart a fjnding that average prehtian losses in these stares 

### io sheep or to sheep and lambs 

### ccmoined have increased sine? 1972. Lamb losses 

### lo all causes 

### as 

### a perceni of 

### lamr crop have increased from an average oF 10.G perceni dur-ing in2 2erigd 1960-71 

### to an 

### average of 12.3 ?ercent during the period 1972 to and including 1981. Wnile this night support an inference chat iamb losses to predators 

### on 

### an overall basis have increased since 1972, the record'does 

### not establish that this is so. Lamb 10sies to predators 

### as a percent of losses 

### to all causes have not increased since 

### 1972. In facc, lamb losses to predators appear 

### to have decl ined since 1978. Individual producers have, hcwever

### , suffered increassd predation losses since 1972 and for some producers it is clear that predation is a very serious problem.12 Ijsues i(5) and 

### (c)

itcould be inferred thac cattle losses 

### to predators were not


### a ?roblem prior 

### to 1972, predator losses cfcalv?s have increased since 1972. Texas isby far the largest goat producing state and
r

### - the evidence supports the conclusion that losses sf sozts 

### to predarorz in Texas have increased since 1972 and thar losses of goars 

### to predators as a percat of losses to all c3oszs hsve also increased 1972. It does qpeay, however, that ?cssesof gcats 

### to predarors declrnea in Texas in 1981


### . 13. Coyotss are by far the principle caus;! ofpreaaTor losses t3 lives-lock. Foxes and/or feral doss Jay be significant ca~szs gf przdation i7 isolatsd instances. Whero predation is causzd by "fsral iogs" it is usually packs of dornescic dogs wnich hav? s~rayed frcm nearby towns or communities


## . Issue 

### 2 

## - Zfficacy 14. The use of 1030 in toxic collars 

### is 1ikely 

### to reduce predation in 

# -7 instances where sheep or goats are cjrazed in 

### ienczd past9res. Ine toxic collar is unlikely 

### to reduce predation on open ranges because of the difficulty of targeting predator attacks to collared animals. 1 Compound 1080 in single-lethal dose baits 

### (SLDs) has not been utilized for the control of predation in the United States. Similar baits containing strychnine, rzferred 

### to as drop-baits, were

% - extensively utilized for that purpose prior 

### to 1972. Because of the concurrent use of strychnine baits and 1080 large-bait stations, it
.A 

### '.". ~~;c-lt tg L;--~-<n~ ia~~i ,,I, llL 21:2

. . (3f -,-

:~C~;.j=_f?~-~
. . t;y +i.fbzr c-nj-~ol 7ethod.


## - 4 ;kzs con+,ai ning 1zSu zrz uszd c-nc-rr?-,tl

### y :?/i'-,h 7

## i;aa 1arvz-5ai 

### t stst'sn,s

, . in BritisnCcl,;;;;bia 

### fr~r the csntrgl 3f :oyo<ss 

### l,vcl v.8 

### zfiz ; i; 

### Austrailia for 

### the control ofdingoes. Expert ceszimcny sst2biishes that 

### SLDs containing Compound 1C80 could be 

### used in conjunction with appropriate scents, 1urzs 

### or draw stations to remove particular

-, depredating coyotzs. Ice effectivefiess of 

### Si9s in xhese circ~mstances would not be 62pend~nt ypon ivhether the 

### livescock :ere grazed in fenc~d ?zstxr?s 

### or on open r2nges. 1 The evidence does not eszablish 

### chat use of'Conoound 1080 in largebaitstaticris is an 2.ffec~ive netnod of predator con;-lrol


## . This conclusion is Sassd upcn che fact that 1ar3ed~ai 

### t .stzt-icns dr2 intmded 

### to suppress area 

### orrqional coycte scpuiazi3ns dnd zhe evidencg i naicates that chi

### s pur~os 5 has 

### not been accompi ished. I i $41 though ic is clear ~hac no metnoa 2f 9reda;or con~roiis ef+xcive under a11 circumstances, ir is 

### not unfair 

### to addrss the questicn of the effectiveness of Compound 1080 iarge-bai

### t stations 

### on the basis of 

### their intended purpose. The declining number of 7C8O bai: stations placed by and the increasing number of strychnine dropbaits uszd in the years imediat~ly preceding 1972 would seem 

### to consti

### tute recognition that 1ar2e-bai

### ts wer. losing their effectiveness


## . The phenomenon of bait shyness may explain at least in part wny 

### 1080 large-bai

### t stations fail to consisi2ntly reduc2 coyote populations and predation.17. ~t is not jib?? t3 dettrnine 

### from the recard how nuch grzdation

, . foxjc ~31,: ars, SLzs or iargz-32; 

### t stations


## . Issue 3 

# - A1ternatives 18. Removal of denning pairs of coyotes 

### or their young may, and frzquenxiy does, 

### stcg livestock predation in localized areas. Zepending cn terrain, tracking coyotes and locating cheir dens zay be very cliff;cul

### -: and tine consuming and i~ any event, rquires sx?erisnce anb 

### sk'lls. Aerial hunting and gunning is probably the most eifxrive way of shoocin; coyotes. Use ofthis method has increased significantly sinc2 the 

### - 1972 order suspending the use of toxicants far prlda~or concroi. ')Leather, c2rrai

### n and veger-ati

### ve cover may render aerial hunxing ineffective 

### ordrasticailjlini

### t i

### ts es'?ec-,iveness

### . In sddi11 on, aerial hunting of csyocss, 3s~eci a1iyfr2m fixed-ni qg a1rcraft, is hazardcus and helicopc~rs ar? very ?x?ensiva. 3un:ing coyotss from the ground is more difficulr and time consuming as they are wary and illusive animals. Trap?ing by the 

### use of steel leg-hold' traps isa traditional and 

## - on2 of the most 2ffective rriethods of predator csntrol



### . iraps, however, frequently becone inoperative in wet and freezing weather,
can be and are disturbed by 1ivestock and non-target aninals, rlquire considerable skill 

### as toplacenent and use of scents or lures and require constant checking 

### to assure operability. Snares may be effective in limited situations, i .e., 

### where coyots or other predators, - attempt 

### to Pass under cr t'ircugn rei.,tzes, -a? jump f3nr,2S

being blown into the opening xnere 

### the snar-es are s2C. 

### 20. A1though bl-45's ar? quite s2lective to coyot2s and foxes, certain soil conditions are corrosive and c<rrosion causc?smechanica1 problems. In aaditicn, heaci5g and cooling of the gni-LSbrlaks the s?als, allcwing 

### misture 

### to ?enetra% 

### the sodium cyanide cartrikge, thus rendering the Oevicz ineffzci-ive. ;!-44's myalso be rendered inoperabl? by 1ives~ock 

### or people and are ineifxtive in warm weatber because coyo~s 3re not aztracz~d 

### to the sc2nrs. 

### 3eczus2 

### of chese problems and <her~scrictions placad cn 

### its bi2 men icIdas

. -. r2gi;t~redin 1975, many ranchers ir? 3i55az? s~~ed '41ch tile ?Tiecxi\/?ness of the 14-34. 21


## . Aversive conaitioning i

### s 

### che use of 

### a cnenical such 3s 1i:hi ilm chlorice (LiCL) in a bait so 

### as to induce an illness in d coyote or other predator. 

### The theory is that the illness 

### wi?1 be associated wi;h 

### a particular ?rey, e.g., 

### a sheep 

### or lanb, and chat thereafter 

### the coyote 

### will refrain frsn attacking particular livestock with whicH the illness is associated. FWS 

### has concluded that aversive conditioning using LiCL isnot effective and that even if an aversion is 2szablisheQ, the length of 

### the aversion would not be sufiieienc 

### to 

### have any substantial effect 

### on predation. Although experiments have 

### been conducted from wnich itmight be ccncluded that aversive conditioning

L using LiCt reduced predatgcn rat2s for limited 

### per~sds of time, variables such 

### as the availability of alternate food sources, theinconclusive. ,& dis;jute 

### ai c3 the detor-nination of coyots kii1s and lack of loss dar2 cast further doubt 

### on the ou;corr,e of the tests. Fioreover, i~i tnesses participating i n ;he 

### t~ts aclcnowledged that the concentration of LiCL was critical 

### to the 3version allegedly escablished, but beyond ass2rring 

### ~hzt itshculd be tne mininurn necessary to produce an iliness, appear2d ~3 :be in doubt


### as to precisely what thatcancr-etration should be. It 'was also acknowledged that t3ere inisht be other more suitable, isss saline
or strong t2stjngm chmicals "Lan LiCL. Itis concliidej. that the 2ffectiveness of aversive condit'oning agenrs as a oethod of ?redator control has not been established. Such acenci \,vcu:d, of course, requir? rqistra~ion by 

### i?A. 22. Fi,iS has test?d.the us2 of diethylstilbestrol as an anxifzrtility agent 

## - or reproductive inhibitor. Ihese tests have been tzrminated 

### , F1,(iS concluding that unti1 

### a more effective reproductive inhibitor than sci1bestrol and a more effective delivery system were developed, reproductive inhibitors offered 1 ittle 7rcrnise of lowering predation. USDA has reached ess2ntially the same conclusion and has terminated all tests of reproductive ichibitors. There is no other evidencz inthe 

### - record 

### as to the effectiveness of reproductive inhibitors in reducing predation. While itiscontznded that termination of the tests was premature, itis obvious that the whole theory of reproductive
---- - inhibitors 

### as a predator control technique is based 

### on the assumption, 17

A' ~nat ihere is2 41reciz relai:anshlj be-.:.i?en -.no nui;z?r -,f ZD?:?S

ana preoarion lasses 

### of iiuesmck. Spponenrs of 

### rne rzgi iiracio~ 

### oi 1083 dispure this zsiumption. 23. Tests 

### of chcqical repellanis as 

### a neans of reducing coyote pr?daxion have been discsnxinuei by FWS and USDA as sflowing no pramise of effective predator control. There is no substantiai evidence in 

### the record to contradicx these conclusions. Strobe-lights, sirens and propane exploders or zon guns have dlia 

### been tested and 

### u:i:izei



### - in attemprs t3 control 

### ar reduca preiatron by c~yotes. tests by the PAS uti1izing sxrabe-1 ignt/siren devices have shown encauraginc results in reducing oredatisn over 1 imiied psriods 

### of time. it 'fitas recognized, however, ihat additional dark was necessary to identify 1 i , e.g., 1ight, so~nd record!ngs 

### , etc., ;ha: iicuid most eilectively resel cayctes. Other evidence in the record is to the effect that 1ighn are corally ineifsccive in reducing coyote predation 2nd that coyotes quick1y become habituared 

### to expioders
or 

### zon guns. It is ccncluded that repellants, chemical or mechanical, have 

### not been shown ro be an effective method of deterring or controlling pradation. 24. Guard dogs have apparently 

### been used to protecx 1ivestock from predatsrs in Europe and Asia for hundreds of yeirs. Guard dogs protect livestock not 

### so much by attacking predators, but simply by their presence deterring predators from attacking lives;ock. The record reveals that in some instances, chiefly small fenced ?astures, guard dogs can be effecclve in reducing predation. Guard dogs are, however, expensive. The purchase price ranging from $300 

### to as much 

### as ~BUU each. Noreover, rhe dogs require extensive trainingin that as much 

### as i;JO ysars TE~ diapse from the xire of acquiring



### -

# - a ?up before 1'. can 3e deierslnec ineraer i 

### I 1 be er:ec~:ve ai a nature dag. 

### Ic is clear ha^ guard do~s require supervisisn 2nd


### a great deal of patient attention, that not every dog will develop 'nto an effective guard dog and that some dogs przy on sheep cney
are suppose to proceci. Although 

### a survey in the record of rlnchers using guard d is in llorth Gakota indicated good o excsl

### Ient resultr

### , ranchers wno ~~stified atthe hearing ~ho attemoted using guard dogs did 

### not have gocd ?x?eriences, indicjting chat it was difficalI 

### t to keep thedogs with the sheep, that the dogs became shee? killers


### or that the dogs wonder;?d onro neighboring ;asturPs and Idere snot., 

### 25. Shed Ianhing can reduce 

### losses of lambs due to weather, lanbing ccmpiications, mainutriiion, dissase and oxher Causes. Yhi

### 1

### e ewes and lambs aro 

### subject 

### to lit~le or no predation duriqg the ~eriod of confinement, $redatjon can begin again or ccntinue once i he sheep are released 

### into pastures 

### or ranges. Shed lambing is labor intensive and is not an alternative method of reducing predation. Herder; 

### are essential to control and lock after sheep in open ranTe si

### tuations , A1though additianal herders cou?d in theory reduce, predation losses, experienced herders are in short supply and the cost of employing and maintaining them (asmuch as 

### $1600 a xonth) nay not be economically feasible. 26. It is theoretically possible to build fences in such 

### a manner as to exclude coyotes. Testimony 

### atthe hearing centered on the question of the effectiveness of electric fencing in reducing predation. Evidence.

## - indicating er~?ctivzness 

### of 2iecxric fmcing chizflj concorned

., Aizhougn aa\~anced cnzrcjers have 

### kende\/el oger lt~h: cn ni nixizs :he likelihood ofvegecaticn shorring 

### out such fences, it is clear tha; electric fencing is nevertheless a high maintenance itern. ??oreo\/er, 

### becaus2'of t2rrain and soil conditions itmay be difficult or impossibie 

### to ccnstruct 

### a fzncz in such 

### a manner that coygces canno1 =ass

### or dig under the fencz. Sdch fences constructtd on open ranse, if effective, rnigh~ well inhibit ;he ,novernenx of dildiif?. In ;he laic and final analysis, however, tne major linitations 

### to exx2nsive 

### use of

7 4. fencing 

### to sxclude czyotes are economic. ioizl 

### cssts fzr ~he construction 

### of such fencing have been estimated to range bet~eon $5 thousand co 

### 510 

### chausand per mile depending cn :be xyps 

### af construction and cerrain. ,Azs~rzions chat ,he cosr of jucn 

### fencins could be arnorxiz?d over 3 seriod 

### ofyears by ske iavinss 

### frzm prldati

### on losses are unrealistic and fail 

### to consider how such co'nstrtictign could be financzd in view of the thin margin upon which sheep producers operace. There is evidence that r5nchers are hard-presszd 

### to maintain che fenc?s they have let alone ccnstruct new ones. It is concluded that 

### fencing 

### is not an effective and economica11y feasible a1ternative method of predation control



### . 27. Penning or corral1ing sheep and 

### goats atnight can 

### be very effective inreducing predation. 

### Ithas no effect on predation that occurs inthe daytime and is confined to farm flock operations as i

### t is 

## - i,:prtic:ica: -:o 12:~ 1z;';e f:scki ,,-ids,-Fczje t:n$i t'>ns, i-.c so-ca: 'led "Kansas Extension System" i

### s, basically an educational and training

L- s~~stez 1;;hercSy r~fichei-sai-e ~dugili tohandle predatlcn problems 

### ontheir own. It is not, however, ?n al'ernaf2 lri"zho0 of srd2tor controi, becaus2 itis chizfiy penning 

### ax nignc tbdc r?sulzs in izw pr2cation ratss in Kansas. 25. Open range situations are grazing conditians under which-itis least like1 y that any current1y avai1zble rnethgd oi predator control wi11 be conristentl effective and economical

### Iy feasible.
Issue 4((1 

## - 3eneiits 23. The number of sheep in the Uniced Statzs has dzciin2d over the last forty years, from a high of 56,574,000 in 1942 t3 3 law of 12,220,QOO in 1979, increasing 

### to 13,176,OCG as 3f January 1, 1982. The deciine 

### - is attributable to declining dernand for 1am~ and 

### rnuxton (per capita consumpti

### on being approximateiy 1.5pounds a?nually) 

### , avai1abi1ity ~f synthetic nateria1s 3s substitstes for 

### wool (per czpita consunpcion ofwool being approximateTy cne pound annually of wnich fiity percznt is imported), the fact that raising cattle is 1ess 1abor intensive than raising skep and more attractive opportunities being available elsewhere. The dec!ine cannot be attributed solely 

### or
even chiefly to gredation. Approximately 80 percent of the sheep in the United States are raised in the 17nost western of the 48 contiguous states. A1though approximately 51,000 western farmers and ranchers raise sheep (1974 data) only 21,000 or 41 percent have comercia1 operations of fifty or more stock sheep. These producers, however, own nearly 93 percent of all stock sheep in the regicn. Large scale producers with a thousand or more of stock sheep constitute only 6 percent of the producers, butacc~unt for 63 percent of the region

### 's stock sheep.

### - 3C. ix7ei-t tstiiccny 

### from witnesses for "is Jroponencs of the ~PC::S~F~;~SR

cne mngpiand in :he :ies:sm United S:aies rquir?s~rzzin~ by catt12 

### sheep and 

### goazi rather than by a sinsle species. Grazing 

### cattle, sheep and goats in the proper combinations 

### and ac suitable intensity not only increases 

### the production of anixal product: per 

### acre, but tends 

### tomaintain the carrying capacity of the 

### land in tha-c sheep 

### and goax can he1p csniro! deeds 2nd brush

### ,'thus avoiding the use of herbicides or expensiv? ~echanical xe~hcds of control. Because sheep and goas have zhe capacity 

### to turn ?asxur? and range \teget;tion 

### inco meatand!fiber ar 

### a relatively 1oi.i cosc, 572 ri5ir;g cost 

### of ?nerg;/ inrecen-r:years has i,~il;lroved the ?r,snornic c:rr;peci;iveA ness of sneep 2nd go2ts rzlatilre bo c~her meax and oi' ~tlooiand

-, , * nonai

### r re1

### azive to syniheric;
. Inis may 2x91a1n ,he r2c2nr inc~ease in she~p numbers. 31. Wjmesses for the proponents of 

### lO8O rqi stratian a150 tzstiii2d chat
areas suitab12 for tre grazing 

### of sheep 

### and goats Iwere 

### not being 

### usilized for that purpose because ofpredation 

### or the f2ar thereof that was forcing the abandonment of many sheep or goat 

### operations. These witnesses asserted that young people 

### wer2 no loncjer enwring the sheep 

### or goat business because ofpredation and that excessive predation was 

### a factor inlending insticutions being unwilling 

### to advanc? capita7 

### for such 

### operations. The result of this situation assert2aly includes alterations in the economy, decreased importance of ?gric8~l+ure tc! +h? er~?rn?

### ?ass. 1 c!e:?ir? 

### ir 'rdust~4ez-~,,k~~cSdepend on and support the a~ricul tsral secyor, and iorczdchang$s in 1ilfing concitions of rur31 famili~s. Yh; I? ~r2ca:;on conczrcs 

### sr? real and in some instanc2r cle?rljjus~ifiea, i; is cancluded that factors listad in finding 29 ra~her than 7rgda:ion iire chisfly responsible for the decline in the number of operators raising sheep and goats in argas suitable for that purpose. 

## - 32. !JSDA conducted a survey of fcmer sheep produce ; 

### 'n Colorado, ,exas, Utah and 'tlyoning. Predation \,vas gi5ier;

### as a sic ificant factor in the decision to discontinue she?? prcduction by f3mer ?roazc2rs in each of tne four sIates, a1though shorrag9 of good hired 1abor, lamb and :vool prices and age of the okvner lrlero other1 si

### snificant reasons. Financial returns were frequently meager or nil 2nd the majority gf fomer producers in lrlyoming ,dere suff~t-i nq operaziona1 1osies, i


### .e

### ., -, not even aee~ing cash costs, wnen :hey discontinued 3roducti~n. III~ number ofsheep praduczrs declified by 12percent in 1973, The 

### par following restrictions on the uie of toxicants, the greatest ,?erc?nta~e of reduction since 1975. This declin? 

### was followed 5y further declines of 5 percent in 1974 and 

### 10 percent in 1375. In Colorado and Texas Eore producers stopped production in 1969 and 1970 than in other years betwegn 1968 and 1974. The biggest decline in number of producers in Nyoming and Utah occurred in 1969 and 1371

### , r?s?ective1,y. Ceclines in these four states in 1973 were not 

### out of1ine with the number of producers discontinuing production in other years. Itis concluded that although predation may have been a factor in producers discontinuing sheep operations, such discontinuance cannot be relaied 

### to the- - - suspension of 

### the use of toxicants 

### as a means of predator control.

### have been ?srima-- ", dc 

### $13 zii1ien 5 year. 3as2d on ?szizatea caif 1osses tocoyocos af0.4 

### percenx in I977 and 1977 pric~s 

### , cacti? 

### producer losses have been sstinated 

### zt $20million. it is assertzd that total 2concmic losses to producers would nearly double if 1980 p~ic25 were used and would nearly quadmple if the higher range 

### of estirnatsd 

### 1oss2s l,qas used. Total economic losses 73 ?roducars frcm coyow predation on.sheep and ca:ves in 1980 hzve been esziinated so 

## - be inthe range 

### cf $75 

### ta SliOilli ion. ;he latter figures ?rs 3?rncst 

### csrtainly far too hich. 34. The USDA survey 

### (Gee, et a1


## .) estimated chat sheep ?reducers los~ $27 niliionto ?reda~ors, wizh cansuners losing an addition 

### 510 sillion due co higher prices and 

### reduced supply. ?~SS~S in foregone lamb 

### sales amcng the approximate 

### 3,OCO ranchers who report26 lamb losses to predators 

### exceeding 10 percent were estimated to average about $4,000. Based on 

### 1977 prices, 

### USDI estimated thac sheep producers lost $19 mil1ion 

### to coyotes and 

### that other producers gained 56 million because of higher prices caused by reduced supply 

### for a total net loss 

### to producers o; $13 mi 11ion. Texas sheep producers
are estimated to have lost $4,317,600 to predators in 1981 and goat producers are estimated 

### to have lost $2,765,450 inthatyear. Dr. Nielson estimahd direct income loss 

### to Utah sheep ranchers becween $3.6 million and $5.6 million annually. The Texas and Utah estimates



### as appearing in

### USOA's statistics and make no allowances for pric2! 

### - chagses caus~d 3y ;qcreaj~d supply. T+e 2ifsc: !s to 3vorszats CC%~ '
~OSS~S. 35. Whether an increase in supply of shes? and lamb would in fact rzsult in

### a decrease in price depends 

### on ~he s2nsicivify ofprice 

### to the quantity sold, which is "Le.med price flexibil ity or price e:asticity 

### efdemand. "Price flexibility" is che percent.age change in price ;.rhich will resulc from 

### a one perccnt change in the quanticy cffered for

L sale, wni 12 "elasticity ofdernand" is bhz eercentage change in q1~nci ty

-1 purchased that resul

### ti: frcm a on2 percznt change inprice. Inere is evidence that :he dernand for lamb is inelastic and thac in view of the fact that only 

### a minbrity of producers suffer gredation loss2s, <he reduced pricss caused by the increas2a supply qight 

### well result in lcwer total revenues co sheep producers 

### as a 

### whel?. Qtnerevicenc? is
ro the effect :hat the denand for lamb is a1asiic;~nd :hat, 

### becluse i 5 I is a luxury 

### or specialty icem, the reduccion in ?ric2 .Xiused by incrla_cedsupply wou1d 

### notoffset increassd revenues r~sui 

### ting from greater quantiti being available far 

### saie, It is concluded that the contention thac th? demand for lamb is inelastic has not been established. Irrespective of whether the demand for lamb is eldstic or inelastic, itis 

### clear, however, that only those producers suffering substantial ~redarion losses would benefit significantly from a reduction in such losses. 

### The evidence indicates that these producers are mostly the large 

### open range operators. 

### 36. Based on 

### the assumption that the demand for lamb is inelastic and upon 

### the further assumption that the average current loss of lambsA 

### 1 percznt reduction in 

### l~sszs to j

### .3 1;iircenLL l,~o~;d incre5s~ lamb product-ion by 53,500 head and 

### gross revenue TO producers by 

### $1.3 mi11ion. A 

### 2 perc2nt r~duction in coyote predation 1osses 

### to 

### 4.: percent would 

### increase lamb production by 

### i07,lGOhead and grms 

### r2venue 

### to she?? producnrs by 32.7 million. ?educing lamo 

### losses 

### t~ 3.5 

### percent would increase prcductign by 160,550 nead 

### and 

### in grcss income co U.S. sheep producsrs by 

### SJ.1 mi1iion. A furlher r2duc;ion to 1.5 percznt would increase lamb produc~ion by 267,750 head and gross income 

### tc prcdQc2rsby 56.3 mi

### 1lian. A 1 p2rcent reduc;~ gn inaverage coyote pr2dation frcm 6.5 percenT 

### to 5.5 ?ercsnt Is in excgss of 15 

### percenx dnd 

### a rnduction incoyotz predation 

### from 6.5 percent to 1.3perc~nt would be a rzduction of approximately 

### 77 percefle. I"Lis clear Ehac reqistratior; ~f Z~m~ounC 10BC :vjl' not elirninate a11 predation and there isno evidence 

### frcm hnich it could be concluded 'hat reducxions of 

### suc~ magnitude are likely from the 

### reregistrat'on cfCompound 

### 108C. :iloreover, 

### siich rgductions in coyote predation wculd hardly be costless and such cost should be deductsd i

### n consiaering overall benefi

### ts

## . 37. Using budgets prepared by the Cccperative Extznsion Servicz of Colorado State University, estimates have been made of the impacts on individual producers of reductions inlamb 

### losses to coyotes for prcduc2rs having 50G, 2,000 2nd 

### 2,100head of sheep, 

### These calcuiations indicate chat 

### ror tne 536 snee+oper*at:uri hcivlng C! reauction in lam^ iosses

### of frcm 

### C.7 7ercant to 3 p?rcsnt, gross incone couid increas2 frcn

, $317 

### to $1,260, ?roCuction CosTj cculd increase frcm 

### 5107 to 

### $429 and returns frsm preda~or contr3l and 

### to nanagsnen: couid incr3as2 from 3212 

### to 5831. The largest benefits would be enjoyed by the 2,400 head sheep operator using range lambing having 

### a reduction in lamb losses ranging from 1.5 percent to 12oercznc. Gross income for this produc2r could increase frcm 51,845 

### to S15,35L and production costs could increase frm $707 to 55,925, resulting in retirns frcn predator control and to management incre2sins from 51,139 

### to 2s much as 

### $9,529. These estimates do not include increases in cost

-, for predator conzrol: inese are, of8 course, sstirnates bas2a 

### on lasses considered to be average or represzntztive and like all averages, ccu13 underest'mate 

### sr over~sti~at2 the financial impact
cn individual pr~ducsrs suffering predation lossss.
Issue 5 

## - Envirm~~en~ai Sfe:;/ 38. 

### In F1,JScescs l~i th toxic col1ars, :ol 1ars 

### ere 1ost

### , others were accidentally punctured 2nd still others probably ?uncmred and not recovered. Lost collars woula 

### mcst lik21y 5e found by the rancher
or 1 ivestock owner ,xilo wcuid be familar wir,~~ tne hazzrds reprgsentoa by 

### the collars. 

### An adult finding 

### an intact collar would be unlikely to open the reservoir,if he noticed the hazard notic? printed thereon. While itis conceivable that a child of tender years might wander into a pasture or other area wnere collared livestock had 

### been kept and find 

### a punctured or leaking collar, get the soiuti~n4. on his hancs and 

### xhen 

### Snw 3:s rcuzh, such a so-jsibilicy is

33. 

### There is 3videnc~ <ha; coyotes bury or ,acne soxic coliars anc collars plus 

### other int~ct cgllars that arz 

### lost ldould 

### 2ventuaily detetliorateallowing :he 

### toxic soliltion 

### to enter the soil
, icappears, however,'that there are certain bacteria inthe soil '~hich operafs to deccxify 

### the soiution. The time 

### required for de~oxi ficat.i~n 1,vouid vary with.the amount 

### of toxicant, soil type, ~smperatilre, etc., but itappears that dsgradat!'on ofCcmpound lC80 nay be acconoiishec! in periods up 

### to eieven \~eeks.Ai though ithas been suggeszzd that punczured, leaking 

## OFdeterioratjng collars might poison water iuppi

### ies, thi? possibility is ccnsid3red to be unlik2ly.


### - 40. ioxic solu~ion is a1so spilled in the course oi

### a coyote ?:tzIck ;vheroby
a collar ispunc~nred. Pen t2sts 'ndicate chat spr2ad of the eye I I 

### after the collors liver? pur?c:urec! by coyotes varied betxeen 

### 12 sq. f-, to 300 

### sq. ft. wi~h 

### the average 

### being 138 sq. 

### ft. Spread of the dye

, deaended 

### on whether the lamb was down or moving 

### at the tine ;he collar was punctured. 

### It'was estimated that 

### an even distributjon of Ccnpound 1080 over the average dyed aroa of 133 sq. ft. would resuit ina concentration of

### 2.2 

### mg/sq.ft. The prospect 

### that such 

### a 

### Icw concentration would cause 

### serious environmental dzrnage is considerxi remote and 

### no such damage has been observed in field tests. ,Another route of potential exposure to non-target species 

### is the carcasses of coyotes poisoned by puncturing toxic collars. Only turk2y vultures

1.h 

### 6;gear to :;a14e 5r134~ii ~2d d,,j: 0

### ",he LdyOk-; fdl~il~ db:'i rig ~,es i2 hicr123 I , th2 

### callar. Scavengers f2edirgon -31 1a~zd iiv2s;cck 

### ti1i 2s by coycczs eonc~ntr~;zd 

### sn visczr3 and . , 

### xe,callars

## .

. also appears that sc?veng?rs 

### fosding c~n collared 1i5i?stockki1;ed b;~ coyotes do noc ordinarily consume neck areas. Dessit2 intmsive searches, non-tar2et deaths r2sulting ircm tzsts with the collars have not been observed by FdS and itis conciuded that the probability of significant poisoning of non-target ~i1dlif? rzsuiting 

### Prcm the
use of 1080 intoxic collars is r2mo~2. 51


### . Exposure of SiD bai~s containing 1

### C.80 t3 con-tarset ~,vi?bl i

fe &?ends, of course, 

### on the rate of application and upon whether the baits
are covered. 

### In this connection Souch gakota's application ~nvisages
a maximum of 

### 10 

### SLD baits per square mile, ,Wontana's applicaticn contemplatss 3 ?axinurn of 25 baic; 3er square mile and ',Jycninc's application apparen~l y ccntmplat$s that the number of baics wi 11 be left 

### to the discretion of the czrtified applica~ors.\iidespread application of such baitswould, of course, incr~ase their ~x~osure to non-target species. While such zxposurs cculd .? reduced if the baits were covered, covering of the baits increases the diifiCU~ ty of retrieving uneatened baits and of monitorins the use ofsuch baits. AST4 Method i-590 (1976) recovxnends that SLD baits be covered. 42. Because the use of 1080 SLD baits apprcved herein is upon 

### the assumption that such use will be limited and for the purpose of taking particular depredating coyotes rather than 

### as 

### a coyote population suppr,ession technique, the risk of non-target exposure under such circumstances

-

# _ -. is considered 

### to be minimal.23

i I 43. ~~YS~J-I 3f Soor' Cisherits and Nild7if2 golicy, ?rior to he suspension

xas rhax fha 

### minizun n~~ker nec2s;ary 

### tz acP,< 2~2 aff 3c~:~i? csyot? management was 10be placed. This 

### was generally incerprzred as requiring orgermicting the placement 

### of not 

### mcre than one station per township. The guide1inzs issued by the Burgau further sta~zd zhax ~ke


### use of 1080 large-baits was a t~chnique- res2rq/edfor arias where ctl:?r contrgl methods had not 

### been effective 7

### n raducing coyot2 po~ul3cion
z3 a desired level 2nd wher? such 

### use would have 

### z minimum 2ffect on non-target wildlife and domestic aninals. Although itis clear chat 

### the total number of baits plac2d 

### declined inthe years imiiiediat~ly pressding the suspension of Compound 1080 in 1972, -here is evidenc2 that the number of bzit stations pi;c@d in aar~icuiar 1ocaliLi3s zzcn year did not vary signifieanrly,and tnai: ",he 

### stations aere ?lac?d inmore 

### or less 3-12 

### sane locations s2ch year. ?laci?g 

### cox nor2 than one large-baic station per cownship I,vas on ;he theory that coyotes, being nore nooile and having larger home rancj?s, kouli be
more apt 

### to cone in contact wit^ and feed on the stdsion wnile snaller, less mobi,le animals 1+1i th 

### smzller i~crneranses, would be 

### less likely 

### tobe exposed to the bait. it 

### is clear, ncweker, that there are no significant 

### areas which may be said 

### to be populated solely by coyotes. Moreover, raptors and other birds, which depend primarily on sight for the location of food sources, are more likely to be exposed to 1080 bait stations.the baits be placzo 3s la2in In? =a1l 

### as ?raczicab:e in kze?ins with saf3ty 

### toneat eating na~mals 2nd bjrds ar,d s3nditions of weati?er and travel. Sai

### ts were also 

### to be removed as early in the spring as weather and travel conditions penittzd, the theory being that chjs would eliminate exposufz 

### to bears and other hibernating animal

### s. Because 

### aidense snow pck and otker raasons, there were ocr3sions when baits could not be renoved and desi~oyed until zarly sumer
or iatsr, lflnich vras long after animals wcu:id be auz of hibernacion. 

### 45. Large baits were to be treatsd at 

### the rate of 1.5 grams of 1680 per 1Otf pounds of bait. ' by usil;g a syrinrj?
or meac pump 2nd making injecxions of the toxic sold~icn ar eveniy

.

### - spaced interval s ~i7: ,?the meat was still 61a.m. 3zcaus2 bone, hide, erc., had to bededucted in derarmining the #,~eish: af he il I bais for app1icat;cn of cha a~propria~ amount of toxic solu~ion, and because of .the field conditions under lrihich -,he ba~ ts wer2 prepar?d, even distribution of the coxic solution in the baits !has difficult 

### or impossible 

### to achieve. 

### 46. A11 but one witness 1,qho participated inor ~rino:das familiar with 

### the 1080 large-baiting program testified that the deaths of non-target species 

### kere ninimal. Searches for target and non-tar3et animals, however, were normally conducted only at the time of disposal of the baits 

### or the remains thereof and such searches varied widely in scope and int2nsicy. 

### The characteristic latency period after the ingestion of C~mpound1080 

### makas itlikely :hat a11 birds and animals poiscned thereby ~ould not die in the imediate vicinity of the bait. Because:A :- of these ~~CTS~S, I I~ I, oroi~zo;e:hi; ;Tany birds 2nd animals soisane~

8 1 --. Z!j ib~0 pier2 iie\j?r Icc-tsd 2nd a2-?~-2+ ! -;'b, -,-a. '7. The c;nient!cn hat 

### Cczocucd !C?3 :i 2 selsc~i~s ;ciio~ Is5a;zd in principle ?art 

### on diifsring ;evels if secsizivi

### zy to 3.2 poiian. Carnivores are in genekal more sensitive 

### to 

### 1080 than orher species, while canines are considered to be especially susceptible thereto. 6

### / 

### - For example, the LDSO of 1OGO for a csyote feeding on 

### a properly dos2d meat bait (treated at the ratr of 1.6grms oer 

### 100 pounds of 

### meat) has been determined 

### to be 0.10 ng/kg, ~hile that for a man is esrimat2d 

### at0.7 

### to 2.1 mg/kg and that for a golden sag1e rancjes frcm 1.25 

### to 5.00 mg/kg. -A 30-gound ioynTe hould therefor. obiain 

### an 

### LD50 dose by consumacion of only 1

### .; ourices of bait aaterial ~reated
as indicated above, while 

### a 150-pound man m,~ould cctzin 

### an LCcO by 

### <re J consu~p~ion of 

### from 17.5ouncss to 162.3 ounces. k solien eagle (averageweight 7 counds) ~culd receive an LJS0 by 

### ccnsumlng irom 4.0 ounces io 15.9 ounces of such bait matariai. ,An LSlO0for 

### a CZJ~OC~ has been 2stirnaczd 

### at0.16 mg/kg. Iiis apparent that LZ5~ values


## - for some species are 

### noi precise and have a consiaerable range. ~escs 

### to establish th2s2 values have obviously not been conducted 

### on humans and the tests 

### on many other species, including coyaies and eagles, have 

### not been conducted 

### on a sufiicien,tnumber of animals that a statistfcal confidence interval can be established. :*oreover, there is evidence 

### that the LD50 value can vary depending on whether he mode of

C' 

# ;, LC, 

### - '[.llf.e :c

# . -'..+:.:'

I 6L2a - 

### . - .

### .. 31' 2::;:nze~ 3- : jc:-se - + would-be letnal

### "ro 50 

### percent 

### of animals tested.-. acmjnis:ta:ioo 15 ,I: 2 :si?,';ll.i bz!~ cr in ,%,a:?r ar.~ -I--- .,c w 

### cz IG
-" tavperatures xay :72~5? a ;reat eT72C; an ik2 :o~i;ii~ 3iTb? 301SCn. 

### 48. Atbough ssveral ~ii ~nesses izstiii.21 322; nan-~ar~e: izecj25, izc: LG~ 

### nj eagles and badgers, were.observed feeding on 1C30 bait itations with
no apparent ill effect;, itis clear ihai speci2s as ell 1s ochers were in i3ct killed by feeding on 

### 1980 baits. itis alio clear, however, th3i the loss of particzlar indl~~iduaii s not generaily 

### a sufficient basis for deterinifiing adverse irnoacts on tne population of a s?ecies as a whoie and that ihere is no orllence :ha: the population ofany non-tar;et 

### species uas advers2lj effscted 

### - -, by 1080 baic sta~ions. 1172evidence does nac eszasiish zhai chis conclusion can be extended 

### to endzngerea s?ecies. Itnust, of
course be recognized tnac 3s 23 jcne species. 2.~., i?e Cd:if~rnia



### ,

;;;cip,nt to have an Condor, loss of a single individual may be s*l--l adverse impact 

### on the population of that spec;?s. 

### 49. In tests conducted by the F,4S to evaluate primary hazards of Compound 1080, dogs and magpies were allowed to f~ed on the
carcasses of coyote killed sheep or cjoats having 7uncixred collars. 

### No ill effects were cbserveci. 1~ gther tests, tvro golden eagles and 

### a rough-legged hawk were orally administered 3 mg of active ingredient 1080 in beef taliow baits each day for four consecutive days. After administration of the third dose one of the eagles showed symptoms-of toxicity, i.e., gross motor irnpsirnent, fluffed feathers and loss of appetite. This eagle recovered in about six days, the other eagle and the hawk showing no apparent ill effects. 

### 50. In further tests 

### to determine secondary poisoning hazards 

### to rapiors, 

### two golden eagles and 

### a rough-legged hawk were fed ground meatI, 33 obcained iron fire coycces, 2sch cgynxe having been administered

. . an arai 

### zsse a? 3 agiig acriie 

### ir~r?a~?nc 

## :;€a. CG~C:~'-Q=-
,, -A- Y~ZS ;he eoi? ssurc. ci food for tkesz birds 

### over ;he 1C-djy perj~b af he test. Inalysi: of :he meat iodicated thac itconzained frsm 1.8 mg/kg to 3.1 mg/kg 1080. No discernible effects from this consurnp~ion of meat containing 1080 were observed. The meat was obtained from skeletal or nuicle tissue of the coyoies and itis recognized thar rapcJrs ordinarily feed first an the viscera sf an animal and that <he viscera might we11 contain higher leveli of 1080 

### or fluorociirat- rosidues. Similar tests conducted wi :!I redtailled hawks resuiied in 2 finding of no toxic eifecis 2nd that in fact, the hawks ga'ned weight. 51


## . The 5 mg/kg 

### ai 1CEO administ3r.d 10 Erie ioyoTeS in :he iesTi referred


### u in finding % Idas approximacelg 31 '.IX~S the eszimatea 

### -)loo af I I 

### ' 0.16 mg/kg and a SLS 5aii of 5 ag 1030 wculd csn:a4n aoorcx;sate!~ three SLaIOOcoses for 

### a 10 kg coyote. ithas been estinaced :ha< a, coyote puncturing a toxic collar would receive 

### a maximum of 10

### mg 1080 

### or approximately 6 LOlOO doses for 

### a 10 kg coyote. It is therefore unlikely that the carcass of a coyote killed by a SLO baii containing 5 

### mg 1080 or by 

### a toxic collar would represent a hazard to raptors. 52. One ofthe difficulties indetermining the primary and secondary hazards 

### tonon-target 

### species from the use of 1030 has be,.OT~ the lack of reliable methods of measuring low levels of 1080 residues in

?. ,.h2s;lt2;

$ :f d::jqJ'5 

### ~~c-*-~- -c L><E- 1- 

## . , ,, p 

### n. TL$: dt,,t: p 3-mav. A - q A -pl*i..la " U,LL. refinement 

### of mare sensitive testing methods, 

### e.g., 

### gas chrornatogrdphysvith electron captur-2 d2t?ctj~~ 3~6 ,T~SSs~?c~TcJIT,~~T:/, h2~2 0r.zi7?d <be "

. . -. detxtion of 128s than 9.1 ppn 11283fn one cjrm s?rn??ss. i';es~ wthgcs ;vill facilitate :or? accuratg a;s?ssxent of the hazards of llCEB. Although current 

### tsst inetnods can detect fluorocitr3t2, flgorocitratewould not be detected in 

### a test for 1080 residues. 53. 

### In otherefforts to determine possible Secondary poisoning hazards from the 

### carcsss~s of coyotes poisoned by 

### 1380,the FVS analyzzd 1080 residues in tissues of coyotes wnich dizd af~er puncturing

1L toxic callars


## . i L was deternined that the average 1OSO ccnc?n~r3i-,i c,n 7

### / in muscle tiss~le of the52 coyot2s 1,vas 0.31 ppn. Ton magpies- were confined ~ith skinned carcasses of czyoczs thar died after ~uncturing toxic coilars with no other food available. ;Ait;kicushfcur biris died and one o? in2 four contained 'I 

### C80 residues, i

### t lcras cc~cl uded that these birds scarved io death. The other six birds appar2nt;y showed no symptoms OFlCSO poisoning. ex per^ tstiizony isto che effect that the metaboli c effects of il uorocitrate vimic diabetes me11itus, which isa quasi-starvation siaw, and that the birds may we71 have died of 1080 poisoning rather than starvation. In cther tests, a coyote was given a massive overdose sf 

### 1280 (?CO 

### mg
or 

### the contents of 

### a toxic collar), a LOlOO being ap7roximately I 

### .8mg. This coyote pias dissected soon after deach and tne soft iisiue fed to one group of magpies for seven days and another group of magpies for two days. Even though the coyote tissue contained substantially

7/ A l.9~~) l:ilrl ii magpie i

### s i

### n the range of 0.6 mg/kg 

### to 1.3 

### mg/kg


## . 

## - *..7 hi~her 

### 1G60 resiaups :ban 

### :vera found jn 

### any coyote 

### killed by punczilrjng

i. ". 

## -t ~3xi c CC~ Izr, 90 ;\/i GO~C~ GT 7nc,3;i1ci;i 39 ',/as 'aaszr-~ad. , , qqrz is

8. 2videnc~ cnat foxss c:ed 2fxr i.ed?ng on vangaroo ra?: scisoned by 

### 1080 used 

### as 

### a rocen~jcide 2nd chaz iOyQE2Sdigd aftsr faeding an ground squirrels poisoned by 

### oats treat2d with 1030. Neverxheless, 

### the FWS tests constitute substantial evidence 

### that the risks of secondary poisoning 

### to non-target wildlife 

### f~en use of the coxic 

### 8



### / 

## - collar 

### are not signiiicant. 

# -- 3. The citric acid or Xrsb cycle is the final 

### mechanjim fgr converting food into energy in plants and animals. Sodium fluoroacetate, ;vh~n ingested, ii metabolized into fl~oroci trax, :vhich inhibi~i actlviiy of ;he enz,me aconi~ase and deprives ~311 

### s of energy. This enzyme inhibition resuits in tne blocking of the 

### YrcS cycle, einicn sec3ndarib blocks glucose metaboiizm, 

### a lesser ecery ~rgducin~ process. 3;ockage of chese proc2sses causes 

### the er,er?y supplid LO be red~c2d to tne point nhera cel1u:ar peneabilizy barriers aro destroyed, resulying in loss of function and finally ce1lu:ar death. The breakdown in intracellular processzs eventually rgsultj in the aopearanc? of 

### gross organ 

### or 

### organ system disorders. Death nay result from 

### gr~dual cardiac failure 

### or ventricular iibri11ation, or progressive depression of the central nervous system with either cardiac 

### or respiratory



### 8/ Defenders emphasize the latency period from the time of ingestion of 

### log0 to 

### the onset of toxic effects and the tendency of poisoned aniaalz to hide an reasons why a19 animal5 and birds goisoned by 1080 bait stat'ovs 

### - wlaeuii; 7kelj LCI 02 Toknu &ridrepi)!tra, I nese facts 

### woui

### a aiso seem .eo 

### make it less likely that 

### the 

### carcasses sf poisoned birds and animals would 

### be available 

### to scavengers.36 fai1ure as cne c3rminal ?vent 3r r~s3i r2~3ry zrrls? fc? 

### 1~,vi ns 52var2 convulsions. Seatn inszrnivzres is c>,ou~b,c 

### ts Se che resulXf cmtral nervous sysxm a'sorders, 56. Tests with 

### rats treated with fluorocitraze have demonscrated zarked kidney damage. ~ests with rats wherein il uorocitrate was administered in drinking water in concentrations as low as 5 ppm for seven days have also shcwn mor?nologicaT damage to tssces. This t2st snowed that chere was some regeneraticn

### , a1chough recovery was not cmplst?, after 21 days. Rars given sub-lethal doses of fluoroc~tra~: have 

### Seen shown LO grow ncm,al?yfor seven conchs acd hen to survive 

### an i ntraperi:onedl 4082-of 71uorocitrat? hich would normal?yhave 

### been fatal


## . This i ndicatzs that a certain tolsrance for fluorocitracs nay be develosed. O~her studies '~ave shown rhac re?eaxi sub-;e:ha! doses of~onofluor~acc~ac~ have increas2d :he cclerance of scme 

### l4 speci2s 

### ,

### e.g

## ., go1den 2agl2s

### , rats, nice 5nd pcssibl;/ rhes~s -nonA?ys. gepeatod sub-lethal doses 

### ofinonofluorccitraie airninis~~rob to dogs, guinea pigs, rabbirs and mallard 

### ducks, however, have accumulated :o lethal levels. The reason more data isn't available 

### on whether fluoroacetate accumuia-ies in an animal isbecause itis so toxic.
Issue 6 

## - Human Safety 57. Sodi

### urn monoiluorcscetate is a white, odor1ess, pcwaery

### , fluoro-crsanj

### c salt similar in

### appearance to flour, powdered sugar or baking powder.. 

### Itis essentially tasteless having only a mild, salty, sour or vinegar 

### taste to indi,vidu;ls. 1: ishighly so:.~b:z in l&:t:r, but reiicivsly37 ". insoluble in organic solvent5 such as ierosene, ~lc~bol, zcs:one, or

,-. -- in anizal 2nd :ili<;<~~b:.. i2ts and 

### c?;; S. ;OC:L.;;I r I~SrZzce',ac?iz absorbed throu~h the cjascrointescinal tract, tnrou~h open 'ijounds and 

### the pulwinary epithel i

### urn (the 1

## : ning coverin; air passages in rhe lungs). It is not considered to be absorbable 

### through intact skin. Monofluoroacetate, in general, is chemicaliy.

### stable due 

### to the strength of the carbonfluorine bond. Scdiurn iluoroacetatp poisonin9 in canines ischaract2rized.by 3 latency period from one-half hour to two hours 

### aftzr insescicn, wnich is r2laced co 

### the metabolic process2s described pr?viousiy (finding 35)

## . In humans the larency period may be as lonQ 

### as fij~e $ours and' death ofany species is usually within 23 hours after ingestion. 

### 58. Reported deazhs actributabl~ to 

### 1080 5ave been in cgnnectior! 1,vizh

-7 itsus? 

### as 

### a rodenticide ratner than 2s us2 as a predaciie. I,rier-? is restimony that 1080 poisonings are difficult co diagnosz and that many poisonings are 

### 1ikely to go unreported. A1though t~o witnesszs who apparmtly suffered adverse effec~s from 

### TO80 ~oisoning testified at the hearing, the preponderance of

### the evidence establishes 

### that individuals handling 1080 in connection with the preparation of baits or 

### toxic collars do not suffer ill effects provided proper precautions 

### are taken. 59. Related to both environinental and human safety

### 'is the matter of possibie misuse of Compound 1080. There is evidence that itwas 

### not possible 

### to monitor or control 

### the application of strychnine drop baits and ,it18 , may be assams.j ha-, sini1arAifficy:r?zs t~culd ze i.tcl;rred ,I I1-e us2. -' 7c G? 7

### 1280

### SLDs. ,sess 

### risks zrs real


## . Ine decisicn rersin, ncit*rever, 1imi

### ts ~he use of 

### 1280 SLSs 

### to sovernmenr ernpioyees and i

### z is considered that this restriction subscantially reauczs ch,e ?ossibilicy of misuse. A1though the record establishes chai here were riolations of regulations and policies concerning the placement and disposal of 1080 bait 

### stations, italso establishes that regulations and policies re1dt;ng-to, i.g

## .,covering of strychnine 

### crcp-bsiii and removal of 1arge-oai

### ts from h;ghi?relevations, wer? impracti;a1 and could not be followed in some instanc2s


### . The use of'such 1arge-bai

### rs is not, however, being approved by ;his iecision. Becausa <he dse of che toxic col1ar requi

### rss conrrol of 1ivestock

### , it i

### s imprac~i cal to 1imit itsus? t3 governrneflt empioyees. Ranchers desiring to us2 the co11ars nust be czrtiiiedapplicacors and i

### t is

### , of course,

-9 posjible that some mi SUS~ wi11 occur. l ni s 90siibi1i~y is noi a sufficient reason for refusing 

### to register the use of 1C80 in toxic col'lars. 

### 60. Efforts 

### to develop 

### an anti

### dote for sadi

### urn 

### i1uoroacetace poisoning have been unsuccessful 

### to date and treatment is sympto~atic, xeaning that there is no specific treatment. 61. The only evidence in rhe record 

### as ts the use of smear posts as a delivery mechanism for Compound 1080 in the control 

### of coyotes is testimony concerning three posts cnnstructed for experimental purposes in the winter of 1956-57. Use of the posts would be in connection with specific attractants and lures and there is no data as to the ccmposition and content of these lures and attractants. Although 

### there is evidence from which itmight be concluded that smear posts3

### 9 dr? 3n eii?t~ive 72rnad of r3yare i~ntrrj1 2nd ;hat thejr 

### use ;ni/a?ves

. . ?1!:isai ririi 33 

### ~tz-iaryc~ ? if,j: 9;;3a~s ~2-i:i-22~ ~~515

I 

### -. sre nat inrencoa for she ;ur?ose of removing speciilc desrsiating coyotes, but are ins:e?d in~ended as a general poeu1at:on suppressins mechanism.
Conclusions i


### . The Administratar properly de~emi ned that reconsideratlcn of

### the 1972 suspension and cancellation order involving uses ai~sm~ound 

# - 1080 for predaisr can-cral (?R l2-2, "arch 9, 1982) 8,+aswarranred and 

### to hold a public hearing ineccordance with 

### 10 CFA ;5J.13?. 

### - 2. Toxic collars and singla-lechal dose baits 

### (SLDs)as delivery mechanisms of Compound 1080 for predator contra1 Iwere either 

### not available or cot ussd in i372 ano consequently, here nor csnsidered inthe 1972 order. Accordingly, all evidence concerning such uses may properly be considsred subsiantial and new wichin the ~eaning of 

### 40 CFR 164.131(a)and 164.132(a). 3. The evidence esrabiishes that Compound 1080 when used in the toxic



### - * collar and in 

### SLDs 3s aurnorized herein can be and is an or-ective method of predator cantrol for ihe removal of jarticular depredaiing coyotes or foxes. 4. Among the concerns ofthe Administrator when the suspension and cancellation order was issued was the impact of the use of Compound 1080 and other toxicants on non-target wildlife and especially 

### on endangered species. The Administra

### tor was concerned about primary
as well as secondary poisoning of non-target species. Althougn the?ossibili

### y 5: s?csnCzr-y 20-son;ns canno: be r-i 5' 

### x;, r?,e2videnc2

a, ?stab11s;?s tna; C2r80cund1Ceg ;\r~enl~sscl, in the xxic c31:at- and ii: SLDs 

### as autnorizzi her2in aces 

### no: ~GS? 2 significant ri5k 13 nontarget

### wi1dlifo. Although there is no antidote for Compound 1080 poisoning and treatment is symptomatic, the record establishes that wich appropr;ac2 precautions Compound 1280 can be ussd for ;redator control as authorized herein $4 

### thout significant or ~lnreascnzbl 

### e risks to hunan health and he environnent. 6. The record 

### daes ncE srzblish that over~ll i3sses cf snes? zr lambs to yredatsrs have increased ii nce 1972. 

## - >leverthe1 ess, for individual producers predafi

### on renains a significant c2use of loss, which available a1ternative means of ?rodator concr3l are not consijtontly efiective in reducing ac costs which are reasonable and feasible. 7. Compound 1080 when used in large-bait stations as a means ofpredator control has not been shown 

### to acccmplish its intended ?urpose, that is, a reduction in area or regional cgyote populations followed by 

### a reduction in predation losses. A1though 

### no generalized reduction in the populations ofnon-target species from the use of 1080 largebaits 

### has been shown, the evidence does 

### not establish that this conclusion is applicable to endangered species, wnich was 3 major
concern underlying the suspension and cancellation order. The burden of proof in these respects is clearly 

### on the applicant. The hazards of 1080 large-baits 

### to endangered or threatened species are clearly substantial. In view thereof and in view of the fact that sheep losses 

### to predators on an overall basis have not been shown

### 41 "i have increased rir,co 1972, it is conc?c;d2dthat t5,e risks do not 

# - e-, c,ut>!zign .he berinfits and ~cdi ficaz'3n ~i ;h2 I ,?/L 2rcer ,di:i resp9cz 

### io tnis 

### i;se of Coinpound 

### YO80 is ncc reauired. Accard!ng;y, the application for registration of Compound 

### !C8O in large-bait stations wi11 be di

### snissed. 8. Although 

### the use of Compound 1080 in smear posts as 

### a means of predator control was not considered in the 7972 suspension and cancellation order, for all that appears 

### snear ?osts arsaloint2nded for <he r2duction of general coyote populations. The burden of ?roof being on the applicant, the appiication f~r this 

### use 

### wii1 be dismissed as ic has not been shown 

### to be effxtive for that ?urpose. 

### 9. The bait delivery unit (30U) i5 not a delivery nechanisx of Compound

>< 1080 for ?relator czntrol coverad by che A6mini:tratar's notic? 

### (16
,Yarch 10, 1982). Consequently, this delivery ~echanism may oat be considera9d 

### or the use tt7ereof authorized by this decisi~n. 10. Substantial new evidence exists with respect to the use of Compound 1080 in ih2 toxic collar and in single lethal dos? (SLD) baits as
means of ?redator control and modification of :he 1972 order to permit these uses of Compound 

### 1080 for predator concrol isrequired.

Because no party has argued that the Adminjstrator's det2rmination that reconsideration of the 1972 suspension and cancellation order 

### was 

### warranted and 

### to hold 

### a public hearing in accordance with 40 CFR 164.131
was improper, itis 

### not necessary 

### to address this suestion.

- Although, 

### as stated atthe outset of this opinion, no part of the decision isdependent upon 

### the validity of the 

### ALJ's ruling 

### thar the decis'cn.. . order would be inade tipon the entirz r2cord, xn;s nattzr s,+?rrants3enti.s~. Counsel for ;?,A have 3;t?rnpzzi ta :crpar~~ec~al ize zvidence ?rgperly admissible and for consideration inchis prcceeding. For ?xanpls, while contending that the principle of finality precludes consideration of pre-1972 evidenca conc3rning fundamental issues such as the effectiveness of 7080, counssi state that itmay he ?spropriate 

### to consider ?re-1972 evidence related to sucn narrow issues as ;he gredaror loss rzt2s and the sizg of the livestock induszry. Itircontznded that the Achinisz~~~or's decision in the 

### M-44proceeding (FIFRA Cocket No. 382, Sept2mber 16, 1975), "L the 2ffsct that-s\ridencs zvai1ab1e pr?or to 1972 coui'd be ccnsidered in detemining the availkbilicy of an antidot2 for scdium cyanide, is not precedent far io;:sl czraiicn of are-i972 evilencz, beczuse the 1972 finding chat there was na anridox was 2rrgneous and noc sdogortzd I' by Ihe record. Csunsel arsue tht; thl~ ruling was ?raper, citing the rule 9

/ -, 

### - concerning an agency's inherent power to correct i:; nistakes. 

### IL is asserted, however, that an agency's power to corroct its aisiakes 

### dces not extend to changing a basic decision 

### or policy, e.g., suspension and cancellation of the use of 1080 as 

### a ?radacide. Under this vie8,q the
more egregious the mistake, the less ?ewer the agency has 

### to correct it. Surely the Administrator has the authority to inquirz into ali findines

9/ While the absence of an effective antidote is aroncj the criteria 

### that may tripaer a Rebuttable Presurnotion Aqainst Registration (RPAR) in accordance w~th 40 CFR-152.11, itis clear that the lack of an antidote is not in and of itself suf-iici?nt reason for either denying an existing
, application for registr-atiion or cancelling an existing registration.
1 - -1 Accordingly, iie exisien~,*a or- I din of ail antidote i; not 2 ;;;ci2? 

### or control1ing finding dnd 

### the decision in the M-44 proceeding would aimos~ cartainly have been the 

### <iancabsent an anridote for sodium cyanide.<I 

### ilpon :uhich tk 1972 

### order mi

### 5a;ed jh~~ld it be 

### considered apnrocriacp 3r 

### qesir:oi? to 

### do so. Counsel fai

### 1 to 

### sxp1ain 

### how !

### Ssuas such as ,,%/hether :bs2 

### rjjk cf 

### grinary and secondary poisoning were overesiimatad in I372 

### can be addressed absent consideratian of

### pre-1972 evidence concerning 

### the impact of 

### 1C80
on ncn-targst wildliie. 

### >!oreover, 

### by focusing on the "newly 2iscovered evidence" requirement of 

### 164.131 (a), which is the requirement to 

### hold a 

### hearing

### , i

### nsuiiici

### ent a

### tten~i on i5 

### given to the 

### 1anguage of 15d.7

### 32(a) providrng in 

### pertinen: ?arr "The 

### det~rnination of these ijsiies ;hal! 

### te 

### iilaae taking in10 account the human and envircnrnenxal risks found by the 

### Adrninistraior in his cancGllation or suspensjon deterninaticn and rhe cumulative 

### eiiect of a1

### l oast and presenz ~ses 

### , i 

### ncluding the 

### requested --/- 

### US~, 

### * 

## * -. I' 

### (emphasis suoplid).

### The 

### cxrnulaiive effect 

### of ai: ~ast 

### and present lses can nardiy b? 

### properly iddressed by 1 

### ri~id lim~tarfcn concerning evidence available only since 1972. Counsel'sconcern that scarce agency r2sources ?/ill be ,vastld in r2litigating issues previously litigated and detemined is understandable, but unwarranted. 

### Since the issuance of 

### the suspension and cancellation order in 

### 1972, the Agency has previously denied applications for registration of 

### 1080 

### and it 

### is clear that applications deemed not meritorious may be deniee in

### accordance with 

### 40 CFR 

### 164.131 

### without 

### a public hearing. This provides ample 

### authority to preclude the necessity of holding a public 

### hearing where substantial new evidence which may materially effect :he 

### prior suspension or cancellation order in accordance with the cited section 

### has not b~:n 

### subrpittod. 

### Y~r-roo~, 

### :./en if 

### a ;r;bl< hearing is 

### granted, the Administrator controls the issues to be adjudicated therein7 F 7 ,. . . 7, accordant? ;qj:h 

### 49 CF? Ia4.131(cj and hzs trip ie a;screc;on i3 3rPcruae

1, 8 the ro-opening 

### of iss~es csnsi2erza ~3 nav? been ?rcceriy bdetz.micedin prior proceedings. For 2xamp12, the ,Adminiscrator night have iini'2c 

### the issues to 1G80 delivery mechanisxs 

### not ccnsidersd in the I972 order, but appears to have chos2n instead that a11 issues in ccnnection with the use of 1080 as a method of predator control would be adjudicated.

. L The Adininii~.rator should not and cannor be rlqu'r-?d ro isnore the fact that a1though the 1972 order misht have been contzsted in administratjve
or judicial proceedings, 

### no such cancest was institutd, and chat fjndings suppcrting the 1372 ordsr remain nighly contr.oversia,1

, tinder these circumstances, rigid prin~iplss of finality appropriat2 fsr t?e caurts
are 

### not applicable and inasnuch as the Administrator*defer7i ned that a11 

### issuns bearing 

### on 'fie 

### I972 order wctild be adjudicated ne~ein, t,ye ,4drrii,ni;traior and the ALJ may, after evidence mee-cing :he srlria of I 154.131

### (a) has been presented cn the record, and consistsnt with 

### 10 

### CF? 164.132,appropriately consider the entire record in determining whether reversal or modification of the 1972 order 

### is required. 32 that 

### as ic may, the 1080 delivery systems authorized herein, the toxic collar and SLD baits, were not considered in the 1972 order and were beyond the scope of that proceeding. Accordingly, there 

### can be 

### no question, but I that evidence whether pre- or post-1972 is properly for consideration. 

### It has been contended that the testimony of Nr. Harry Loats, a witness for USDA who sponsored a mathematical model projecting the?ffzctiveness of Compound 1080 larg? 5ai: itaxions in retucing przda~or iosszs of s?e$? 2nd ?ifer,ts 

### on non-carset ldlife ~cpul a~i ons bas?< sn data from the LS;! 

### of such s:acions in '!liycming during the y.ar 1975-7'7, should 

### not have 

### bean admitted or if properly adnitczd, should not be given any weight, because 

### the model was not produced for 

### use by counsel

. ,in cross-exanination. Rr. Loazs

### ' testimony has not been found 

### to be persuasive for reasons, among others, that the model failed to cgnsider imigraxion of coyotes, possible "bait shyness" and assumed :ha: she
resource base renatned fixsd. The objections, howevsr, 

### are rejected as
, lacking inmerit 2ssentially for the reasons s?t far3in the USOA ?eplj 1

### o/ 3riei, thac is, counsel had access to Texas A&?! Ilniverslty (TRNU)'- and 

### other data upon which the model was based, but failed f3 'mke use of
sucn data. Couns21 object2d to having the analysis run and dis?layed 

### on

. . The nicroc~mpu~2r presenx in 

### the hearing room and are no: in 

### a 20s;::cn tc.complain i i; such a showing night hal~e ~hrownadditi2nal 1ign?: 

### cn operation of rhe model and sugest2d additional questions for crossexamination. Moreover, 

### carefu1 examinati

### on of the transc7.ipt rp_vea 15 that a1though ?lr. Loats did 

### state that the model (computer codes) das considered 

### to be proprietary, he did not flatly refuse 

### to producs it, but stated that he would have to consider the matter. Itappears chat 

### Mr. Loats did 

### not fully understand the nature of a pro~ective order that might have been issued by the ALJ in order 

### to protect the data from unauthorized disclosure. In any event, the matter 

### was 

### not pursued by counsel and nay not 

### now be used as 

### a basis for objecting 

### to i4r. Loats'

!O/ USE!, 

### assert: tkt the TAXU 

### data were avai

### iabie to counsel for 

### EPA 

### and Defenders as early 

### as April 1982., 

### . The e1,j rjenc2 2jtsbiishes that ~~cmoo!,~nfl 1sZ0 ar;e-Ga? cs ar? intended

, . as 3 general coyota jopuiatisn iuporession 'ec!?nl;ce frcn l,vn:ih it

### ir

, I . ,. assuned that oenefi

### ts in tne fom of r~dilcti~ns in ?redation ioss?~ 1,4i i1 flow. Wyoming, the applicant for registrztion of 1080 large-baiis, has not established thac use of 

### such baits reduces coyotz populations over large areas or thzt reducrions in ?redator losses of livestock result from such use. In short, the effecriveness 

### oi1020 large-baits 3s 

### a predaxor conrrol technique has not been pstablished. This being so and the risks 

### to &L least endangered and threatened specizs frcm such uses not having been shown 

### to have been overest~mated in 1272, the applicanr1l/ 

## - has not met izs burden of-proving that the benefiTi outweigh' %e risks. This concl,usicn isbuttressed by che fact thac overall losses ~i sheep and lambs to ?reca~ors have not be5n shown 

### lo have incrersed since 1972. Accordingly, nodification of the 1972 order with respect za 1C60 1zr:ebaits is noc required 2nd me application for tne registrztion of 1080 in large-baits will be dismissed. Different considerations apply to the us2 cf lQ80in toxic collars and in single-lethal Cose 

### (SLD) baits. Toxic collars are clearly for 

### rhe rsmoval of parricular de?rsdaiing coyotes and fox25 and the findjngi herein establish that 1080 in the toxic collar can 

### be used iichbuc unreasonable risks to health and the environment. 

### If scatt2red or spread over wide areas, 1C80 in SLD baits might also be used as 

### a general coyote population suppression technique. Such use is open to the same objections as 1080 in large-baits, its effectiveness has not been

11/ 

### Itis a well established principle that where ihe evidence does 

### not pKponderate infavor of one conciusiur~iii 

### an. ths paitj: h;vl-: the burden of proof 

### on that issue cannot prevail.?roved. The lin~xed use of 1080 in Si3 baits auchorizzd her2ir: is caszz

1. 2n xsx;ccr,j. :il2: sk:n :31cs 

### ~szd :n :2nJcnc~i:n isprsc+iz:? ;sr-.ls

F

## - L ' and scsncs can 22 S~TSC ~:ve i

### n r?.r,o\iing parxical.r depredacii;g c3yc-,ss ;~ithoux undue risks to non-target, species. !L is concluded r,hat the hazards of 

### lC80 in toxic collars and 

### SLD baits 

### as authorized herein are sufficiently minimal hat broad prohibitions 

### on their 

### use +thin the range of endansered species are not required. The result ~,vould, oc course, be different, if, for ~xarnple,iE was 

### shown thaz miangered species 

### such as 

### the Sdn Joaquin kit f3x (~er2 in the ar2a and that they mightattack collared livestock or be attrac~ed by scnnTs designed for 12/ 

## - - co~yotes. 

### For all that appears, us2 of lC8O inthe sxear POST is intended 

### as


### a general coyote pogulazion ruppressicn xci?niqiie2nd chis 2pplicacion is being disrnisszd for the same reason as the appiicatjon for us? of 1080 in large-baits, i.e., ithas not been 

### scewn to be 

### sffeczive fqr the intended purposz. Nyorning, 

### et a1


### . have contended that the evi'dence issufficient to registgr 

### the bait delivery unit 

### (BDU) tzsted by Jr. Powarc (70~ 1

### , supra) as a means of ?redator con~rol
, 1: 

### is iqell settled, however, 

### that 

### the issues in 

### a suspension or cancellaxion proc2eding may not be expanded 

### to include us?s 

### or restrictions not proposed inthe notice issued by the Administrator. Shell Oil Carn~anv,

### et al., FIF4A Docket 

# --- - Nos. 401, eta1

## . (Decision on Interlocutory Appeal, April 9, 1979).

12/ Because Executive 

### Order No. 11643, February 8, 1972 (37 FR 2875)) prohiEting the use of toxicants 

### on Federal lands for predator control 

### has been revoked (47 FR 

### No. 20, at 4223, January 27: 

### 1982), no ~rohibici=n of the 

### use of toxic collars and SLD baits 

### as authorized herein 

### on Federal lands is being imposed.18 The r3t;onale for 13i s decision is :Sac und3r :ke stacuze gnly :he Adninis:ra;or or his de;?sate can issue a notjce of iflt2flt to ~2n~2i Gr suspend and chaz such a notice neczssarily ~2~5 

### che sczndard of r2hvance

7-1 for che conduct of he hearing. ine instant hearins is being conduct?d under Section 6 of che Act and the sane reasoning isapplicable. Accordingly, the ALJ has no auihority to direct thac the BDG be registered 

### as a means of predazor con~rol. The use restric~ions for 1080 in SLD baics imposed herein bear littl? re1ationship to chos2 proposed by ;he applicants. Stringent limi~ations ara being placcd 

### on <he ase of such baits, hc~t~ever, because the evidencz justifying cheir lis2 is based 

### on effectiveness in renoving pariicular depredating coygtes

## . US&restrictions (Attzchnenx 

### C) are considered to 52 fully consist2nt with that purpose. No effort has be~n nade 

### to deal with all of the multitudinous proposed findings of fact and arguments raised by the parties. The findings herein are deemed 

### to be fully suppor-r,edby rhe record and the conclusions are consioer2d 

### to be required by the findings. 13 

### /conclusionThe applicacions for registration or emergency exemption for 

### cne
use of 

### iC80 in large-bait stations and smear posts are dismissed.

13/ The notice of hearing issued by the Administrator specified thatthe ALJ would issue an initial decision. Unless appealed in accordance with 40 CFR 16A.101, @r upless the Adasristrator decides t9 review the same sua sponte as therein set forth, this decision will become the final decision of the Administrator in accordance with 40 CiR 164.90.

## - granted



### .

Oated rhis 22nd day of October 1982.

Attachments A, 3 and 

### C

14/ 

### It isclear that this decision does not constitute registration for tg uses authorized. Applications for regis

### treiion wi 11 be processed in accordance with and 

### must confom 

### to usual procedures and regulations.I;lhetiler av:i 1aal? ddla denons:ra~2 in$< ?rec!az;cn oss rases nav5 

### increases slnc2 1972: (a) for sheep (b) for cattle (c) for goats Whether current losses 

### to credation account for a greaEer ~ercentage 

### of total losszs than before 1972: (a) for sh~eo (b) for cattle (c) for goats Yhether coyotes, foxes, and/ar feral dogs are i!gnificanr causes of predation.
7 

## -. Efficacy
I Whetner use of lC8O in coxic callars, single-lethal dose ka? ts, and/or 

### 1arge-baic i~3iiofis is 1

### : keiy 

### to rnduce preda-ign : (a) in open -range grazing 

### of 1ivestocx (b) in fenced pasiuro grazing of livestock 

### 1f use af 1380 is 1ihe

### Iy 

### to reduce ?reda~i cn , by LOWmuch? 3. ,A7cerna

### tives Nhether non-chemical methods of predatar control, e.g., denning, shooting, trapping, and snaring, are generally effective in reducing predacon. Whether the M-44 device using sodium cyanide isgenerally sn effective alzrnacive to the use of 

### 1960. Whether non-lethal chemical methods ofpredator control, e.g., taste aversion chemicals, reproduction inhibitors, and repelldnts, are effective. whether husbandry practices, e.g., 

### use of guard dogs, shed lambing, and additional herders, are generally effective inreducing predati

### on

## .!,li th respect to a?1 a? ternatives to 1983 oi-?sjacid&s, !,qke<h2rt5~r-g

,. . I, is

. any - si:uatlon in ltin?~~ no curr3ntly avdilzgr? 3]t?rnatS\!? is 

## -

. -? >aL Is~~ctory, 2..g. , because of ics ccsz or because of j injtltjcns on its us? 3i!e to characteristics o= t$e control method, ' .
Nhat are the national, regional, 2nd local effects of predation on the livestock industry and the general economy?

' What impact would the availabi1i

### ty of 1380 have 

### on che profits sf individual ranchers and the 1ivestock industry, as a ldhole? 5. Environmental Safety Whether available data,indicat~ that use oi lSSO in ~sx'c collars and/or SLD baits wculd be 1ikely 

### to r9sul

### t in lower direcx or indirsct exposur? to non-tarcyet l,.ii1dlif?than resulted frcm us2 of 1C8O larcjebait stations. 'dhether available data indicate that the risk of primary andjor secondary poisoning was overestimated in 1972. 6. 

### Human Saisty' 'Ahether US? of 

### 1380 in toxic collars, SL3 baits, and/or larrjebait stations 

### is likely to result in human injury or dea;h. 1,dhetheran antidote and/or medical treatxen~ sxists which eff2ctic/ely cauntzracts the effects of 1080 poisoning

### . 7. Use Restrictions Whether prohibition of the use of 1C80 in the range 

### of certain protected and/cr endangered species, e.g., ihe San Joaquin kit fox or California.Condor, would effectively reduce or eliminato the risks to tho52 species, and what effect would such a prohibition have: 

### (a) in those areas (b) on the 1ivestock industry as a whole Whether restrict'ion of the use or' 1080 

### to trained Government employees 

### or certified applicators would reduce human and environmental risks without substantial ly reducing benefits

## . Whether 

### a requirernent iha

### t 1 ivestock predation be veriiied by state employees before use of 1080 was authorized would limit use of 1080 to sit!!ations inwhich itwas most likely to ppqvide signif'cznt benefits

## .Whetner users inould be required :a post warnings in 

### me vicinity 

### of 

### SLD b&i

### ts and iarcje-bait stations. Whether 

### users snould be required to

### check ioxlc collars, 

### SLD baixi, and bait stations periodical1y. Vherher users should be required 

### to keep rocords of rheir use 

### of 1080, and i iso, wnac 

### records. Yhether other raszrictions waula reduce risks 

### withcut iubstan~;ai ?y reuuc'ng oe~eii 2s.Fttacnment 

### 8

1.

aPrzdacion Loss 

### Rates A. Sheep Losses Prior 

### to 1972 3. Sheep Losses After 1972 

### r'; C. Caczle LOSSBS 

### 0. Goat Losses


### TI. Efficacy

, 

### - A. ~oxic Collars ' 

### B. Single-12thaI-Dos2 3ai~s (SLZs) - C. Large-aai t Stati3ns



# - A. Uenning, Shooting, Ir3pping, Snaring 

### 8. ;1-44 C. Aversive Conditioning D. Repr~ductive Inhibitors 

### i. Chemical Repellan~s 

### F. Husbandry Practices (1) Guard Dogs (2) Shed Lambing (3) Additional Herders (4) Fencing

I 

### ,5j Pmin:7; 

### or >ru~lli?~ G. 

### Mechanical Repel1ants\1

## . Environmental Safety A. 

### Exposure' (1) Toxic Collars 131 

## - 13.1



### 8. Risks of Primary and Seccndary Poisoning (1) Primary 

### - 135

# - 136 138

# - 123

VI. 

### aurnan Safety i I A. Physical Prdpercies of 1033 and Stinan injuries 

### - l5i 8. Misuse C. ~ntidote and Treatment


### VII. Use Restrictions 

# - Attachment C


### VIII. 

### Smear Post 136 

## - 157i

, The Ca: 

### n Cornmii~ee, her2inaiter iain or Caln, eia1


## ., :./nose reocrz was ihe primary basis for the 1372 order suspending and cancelling registrations o? Compouna lO8O for tne control of predators, referred 

### to a study conducted by. Utah State Ilni:ler;icy, hereinai~sr'the

I 1 1

### / 

### - Nielsen-Curie study, 

### on 3 23 Fsrcen: sdrno!

### n of &;ah 's shees ranchers. The ranchers were asked t3 ?stiqa;s tkir i3~ai losses 3ur:ng 122 Fiscal Year 1963-69 and ta repor- ihe ounaer 3f shes? iasi ;3 predators. The result showed an 3verage ?redator loss of 61 iwes and lambs per 

### i;000 ewes, 'of which dpnroxi~ateiy 

### ?/I:verz co 1ambs. Oa~a 

### on he 1amb crop per 1

### ,CCO swes :.ier- 

### no, ita:ed, b~i de~ending 

### on t!?atla~a, jredator lssies Ners 2 Terceni 

### of ;ne ewes, 

### 4 to 5 percrnr of the 'anbs and ~er~ass 3 serceni sf the btal flocks. Coyotes were reporteo 2s aeing rhe m;or cius2 oipr?ditsr 1oss. 2. Cain, et al. also referred to estimates compiled by izhe Oirector of the Division 

### of Wildlife Servic2s for the State of Utah during the period of the sarly 1040's 

### to 1965, rlferred 

### to as the Owen Xorse estimates. These estimates 

### were cornpi1ed from yearly reports furnished by a leading sheep rancher ineach ccunty, who in turn contacted sheepmen in his county for data 

### on sheep losses. Cata reported were in terns of actual numbers of sheep lost and not

- 1/ Pursuant 

### to a motion filed by counsel for EPA, which vas 

### not ~nnnc~~j h;/ ?c;, nart.7, n<44~;31 mnA;-~

# -- +-la-- 

### -- LLrr--- v"Uu CJ, ul I ILlu 8 IIVLILS. ; L~ACII u; LII~ re~ura upon wnich the 1972 suspension and cancellation order was based.3ercentases. 3y civicing the to<;: flumS2r of sheep in the stac2 as I

Cain arrived a: jercsnta~?s 

### 07 13552s ;3 jredat'cn ;n the range of 7-10 percent in th2 lat2 1923's and 10~~2s of 2 

### to 4 percent sinc3 that time. Cain, eta1

## . observed that this result was in clos? agreement with the Nielsen-Curl

### e Study for 1969. 3. The Division of Nildlife Services ccmpiied loss data, referrpd to
as the Reynoids and 2ust.d Sumari?~, as reported by the Crcp and Livestock Reporti

### n~ Services for the 5tazes of Yontana , ',!/yomi ng, Colorado and Tzxas. In :he courss of regular annual surveys, conducted by maii questfonnaire, stockmen i

### n, the 1isted states ;vere asked to regort the numbers of sheep lost 

### to ?r:dacors during che years 1366 to 1969. Losszs reported as a gercentage ofall sheep and 1arnbs ranged from '3.6 percznt in Texas in 1967 to 7.9 ?ercent in Wyoming in 1969. Extrapolating this data to 16 wesi2rn SY~WS, Reynolds and Gustad concluded that predators 

### were responsible for 24.8 percent of all sheep and lamb deaths or 5.3 9ercent of the total inventory

## . 4. Cain, et al. alsa had available USGA Forest Service estimates which
are based 

### on records maintained by district rangers as 

### to the numbers of livestock placed in national forests at the beginning of each grazing season and the number removed at the end of the each
season. The difference between the two figures constitutes theincluding those 

### to predators. Resulk, c:zpi~cd for Utah >fatignai Forests, showed losses tc przda~crs ranging beF,veen 0.4 and 1 

### .Q 2ercznt of

### herds grazed. Secause rhe grazing s2ason Oi7 national forests 1as"Lon1y two to thre~, ronths.of the year and because 1osses during

1 I c1th2r seasons, 3specia17:j :vinxr,rihich nay Se subsr,antlai are 

### not

r. incil~ded, Cain concluded chat thesz ~:?ures agrred r3asonabiy dell wi~n the Pli?lsen-Cilr'le aca Owen Yorse estimat2s for the zntire year. 3. Cain, 

### et 31. alsa had a?tai!abl2 dam,on,inventorfes of sheep 2s of January 1 of sach yezr, lamb crop and to~al losses to a!l


### causes as raporr,sd by USZA's 

### Stzsistical ,?e?ortingSerxlice(32s). These damare compiled tnrougn 

### nail queszicnnairs 2nd do noc anernpt to br~akdownlssses to cause. !ctz! losses thus repcrc2d varied betwe 

### n 9 and 

### 11 9ercent in Utah (individual years ranging 

### between 7.9 and 14.9); between 7 and 8 percznt in Idaho (6.1 and 16.1 for extremes) ; and between 8 and 9 percent in Wyoming (5.4 and 13.5 for
3 the extremes) during the same period. Cain, et a1
, recarded thes? total reported 1osses as setting a cei1i ng 

### on, predation 1

### asses

## . 3as2d


### on an analysis of the Nielsen-Curle data, the committee concluded tkat nost operators experienced ininor losses in z2ms of 

### percenIages (with 80 percent of the 

### total falling in the 

### two lowest classes), while only


### a small fraction of the operators experienced heavy losses.,-I =, al.,zutilorzi a:] 3rr~icle "?r?datsr LCS~~S I:: 2ne 

# - r 7

~ock of Shes? and Goats

### ,",dhich re?ort?d 

### on losses co flocks ~aintained oy the Texas Agricultural fxperiment Station. Sheep losses to przda~ors during the five-year period 1967 through 1971 averaged approximatel

### y 3

### -4 percenx of the inventory, while losses co a11 causes averaced

-.., 9.27 percent of the inventory. lnese sercentages include loss2s co 1ainbs

### , which !+/ere considered essi?ni-,iall y post-marking 

### as 1amoing

. occurred in c~nfinesent. ?redator 108~2~ as a percent of a11 

### ;asses averaged 

### 36.30 percenx, the highest being Q2.143ercent in 

### 1577 ana <he lowest being 25.32 perc2nt 

### of all losses in 1969. For tne mos: cart, animals were ooserved and losses recsrded ,3n a daily casis. Coyotzs or possibly 

### a hybridization of coymes and th2 red l~o?f 2

### 1 

### - were the prihci?ai ?r~da~or, this hybridization being csnsicerd
a possible explanation Tor the fact adult sheep were readily killed, while coyotes, which are not hybrids, tznd 

### to pr2y more hezvily 

### on 1ambs. Predation 1osses werE stated to be considerably underestinated because, unless the carcass was observed shortly after the ki1l 

### , it would be scavenged by vultures, making impossible accurate determination of the cause ofdeath.. These losses were incurred despite intense efforts to prevent predation and predation control efforts at 

### a level



### C/ Mr. Roy Yc3rile (find;[ig c5 infra; consi~ered this cross-breeding or hybridization as 

### a possible reason for the exrinction or near extinction of the red WO~ f.

### -

# - 1 1-- , crp?::er :>rn 

### rne .v?czc >, 3r~cu:arcsul 2i73ri. I , :zs 

## - 11

### - n a;pdrenti;i not dsed in rnls arza ~ricr rs IY,~, sir;,,-;nlne sadjum clianiie, tne la~ter i~ the royot. gei-ec, piere 

### .red.


## -9 

### i. ;ne forqoing makes 

### !tclear 

### chat dara 

### on pre-1372 prodaiion lcsses to sheep are fra~nentary and that no sne loss figure is pcssible.


## - he most reasonable conclusion, however, is that predation 10~~2s '>

1 of sheep are somewhere between 3.6 and 7.J oercsnt reporred in :he ?eynolls and Gustad surrmariss. Cain, 2t a1


## . had questioned tha Reynolds and Gustad data because it iiilplied thzt precs:!sn :vas a iilajar
causa of totas1 losses, which )was quesiioned, becruse of ihe s~aristic.1 dis~ricution 

### of predztion losses, i.e., only 

### a small ~r3pcortion of ihe producers suffering major predaiian 1asses.



### 8. In 1975, 

### a mil questionnaire to determine sheep and iano

# :asses to gredatars in 15 western st?

### .es in 197a !,vascsnducted by the Statistical &porting Service of the U.S. Department of Agriculture (Agricul

### tural Econornic Report No. 369, lpri1 1977, hereiaaftor Gee, 

### eta1.). Of 28,000 questionnaires mailed, responses were received from 8,910 farmers and ranchers or 32 percant representingall siz3s 2nd tySas sf 52-9 nser?:icns and zli cjmgraph?caI 2723s

- 

### - si- 15I,l;eszrn ST~:~S. $3ins~ire re1iabil ':I, 3 safin;? l~f ':;:CS~

-, 

### . I 

### not rsspondincj was c3n:acced by v~ai l 

### ?.na personal inervisl,~. in? i was rhe nosL comprehensive sGrvey of she~p and ianb iosszs to predation evzt conductzd. Predation, principally by the coyote, was the 

### major cause 

### aisheep and lamb deaths during 1974, l~sses attributd to coygxes numbering 728,000 lambs and 

### 229,COO adulc sheep, represmting a ~hird of the tots1 lamb deachs t3 all causes and 

### a faurrh 

### of tne adulr sfieey dea-ths. Lanos were attacked mch


### more than adult sheep, overall ios3es to coyot2s being 

### 8 percen1 of the lambs and 2-3 DePcent a? the sheep. Loss ratzs of lambs and sheep 

### to coyoces were highest instates wizh 

### pubiic range grazing and mountaincus t2rrzin ?/hi 12 ccmparacively few deaths 

### frcm cgyotes
were incurred in the Scat2s o-f Kansas, >lebraskaand ?/ortn2nd Souc!~

II I Dakota. Predation losses other than to coyo-ces, ccns~i:uzxi 2.3 percent of lambs and 0.9 perc2nt of sheep. 9. 

### Gee, et a1
, rspcrt2d that lambs lost -co predators constituted 11

### .4percent of lambs born and 49.3 qercent of losses of lambs 

### to a11 causes. Adul

### t sheep lost 

### to ?redaters totaled 3 

### :4 percent of the January 1 inventory and constituted approximately 33 percent of

## . .1 <?a:ns LO dl I c2dses. 522, OT 2'. fzrzn?r :nc7c2tsa :PI?: ;~CD 1055 rates i3 31

## : CdUi2S nave been incrediing

### , lwhiia sheep ; $55 rates have lee3 declining slign~ly.The 

### Gee repor: sza:eC ;hat lt,hi?e most of ihe idr-92 scale sneep ogeracors reporzed losses 

### frcm less than 5 percenr 

### to more xhan 20 percenr, many small scale 7roducers had no predation problems.

, I 1 10. :Ir. Gary Liizauer, a lwi?dlifemanzgement specialiic fzr :iew :4exico Jegartnent of Agrical

### xreand 

### a (wi tnesi i3r 

### Yycmi~g, 2: a1
, suminarizeb she" and lamb 10si2~ beizre and af-.er 1972 fsr ei~ht
sca~es inwhich cornoarable data were available. ,??lying on daca collacted froni iurveys by the Colorado Degartinenx 

### of Agriczlrure as repor~ed inGee, 

### et 31

### ., (~hich indicated lambs lost ;o predazcrs as
a percent of iambs born were 3.2 in 1966, 7.2 in 

### 1970 and 7.i perceni in 1971 as compared 

### to 16.5percent in 197J as 

### r.,- onort2d Sy Gee, eta1


### ., ?it-. Lit~auer concluded that lambs lost to nrela~ors
more than doubled. Adult sheep lost to predatc:~

### as a percenr. of srock sheep on hand as of January 1 of each year in Coiorado >,qere 

### 2.5 percent in 1966, 2.2 percent in 1970 and 3.3 percen; in 1971. 

### The comparable Ses I lcjure for adult sheep 1orc 

### to predators for 

### the year 197a inColorado was 3.5 percont.m 8 1974, the 1a"L~r based 

### sn Gee, ?'i 31. i:.ie losses at~ributec zo predation 

### iiere 2.6 perc2nt of inventory in 197Q-71 and 2.8 ?ercznc in 1972-73. These figures are to be compared with the 1.8percent of stock sheep lost 

### to coyotes in Idaho 

### in 1974 (2.0 percent losc to predators) reported by Ges, 2ta1


## . The 1970-71 and 1972-73 loss data are based 2n 

### a study of range 

### jhee? operaIors, 

### which ?rescnably would have higher loss rates tgan farm flock operations. 12. Lambs lost 

### to predatcrz in Xontana as co a percgnt of lambs born cotaledi 7.3 

### percent In 1968, 5.1 percent in 1969 and 17.5 percent in 1974. The rnajori

### ty of ttle losses (13.3perc~ct) in 1974 were 

### ta coyotes. Adult sheep lost zo predators 

### in >loncanafor ~he above year; as a percenTage of stock sheep on hand as 3f January 1 constituted 1.5percent in 

### 1968, 1.5jercenr 

### in 1969 and 

### 6 perc2nc in 1974. All of these figures a?pear in G?e, ec al., the source of the 

### loss co predators for 1968 and 1969 being the Nontana Crop and Livestgck Reporting Servic2. 13. For Nebraska, lambs 

### lost to predators as a percont of lambs born totaled 7 percent in 1971, 8 percent in 1972, 8.7 percent in 1973 2nd 1.8 percent in 1974. Adult sheep lost to predators as a percent of stock sheep on hand 

### as of January 1 totaled 3 percent in 1971, 3.5". -. ;:;ares irefrcn 

### Gee, 2; 2].,cbe szs;~. s= ilii 

### ;:gsres j~7:, 1,972 and 1973 being !iebraska Li\/2s:3ck isji Reports (1 972-7<)


### . 14. In 

### Yew i.lexico, iamhs lost 

### to predarors as a percent of lambs borr; !were 5.2prcent in 1972, 5.5 percent in:973, 5.18 percent in 1975 and 7.35 percent in 1975. These results, which are based on surveys 3f 99 r3nchus insouihe~s;ernNew Xexico (81 rzncSes in 1975 and 75 ranches in 1976) are l imited i9 posr-dock:ns 

### ICS~PS and are ro be com~ared wizh the 17.1 perceqt lcss rat. ss 

### a percentase of 

### 1ambs born in 1374 reporrea sy Gee, 9: a1


## . ,Adu;r snesp lost t? predators as cmpiled by 

### ,Yr.Littauer, based on surveys sponsorzd by :he ~VerNexica 'Xaoigrchers, 

### show a precacjon

. C loss raze 

### sr 2.5 percent in 1970, 3.5 percent in i371 and 1272. 6.1 percent in 1973 and 

### 9.6percenc in 1974. Tbese data aer. collected 

### Yron 33 ranches in a r sponscred by rhe Yew :?exits Voolgrowers, Inc. inwhich the ranchers were asked to regart on

-1 predation losses for the preceding five years. inese results are :a be compared wi:h the ioss rate of adult sheep 

### to predators reparted by Gee for :dew hlexico in 1974 of 5.9 perceni. Losses of lambs 

### to predators 

### as 

### a percenrage of lambs born in South Dakota were 1.2percent in 1963, 2.3 percent in I970 and 3 percent in 1974. Losses 

### of adult shaep 

### as a percentage of stockfron Sou~h CakotB Livestock and Poultry Lossss (1

### 370)

## . A tab1e compiled from USOA SRS datz showing lcsses of sheep and lmbs 

### to a1i causes in South Dakota for the ,years 1960 to and inc'uding 1981 shows that combined losses ranged fron 

### a low of 5.5 perc~nt in 1961 to 

### a high of 9.3 percent in 1367, {were3.7 ?erc2nt in 1977, aca

in 1977, declining to 8.a perc2nt in 138;. Lamb de3chs 

### to a11
causes 

### as a perc2ntage of lambs docked ranged fron a ics,vof 7.3 percent in 1961 t3 a hish of 13.0 in 1971

### , ere 12.3percent in 1972, and ranged 

### frsrii a low of 70.7 Fercenx in 1373 

### to 5 iiich of

1 ' 12.47ercent in 1379, declining to 11.3percent :n 

### 19S1, Losses of

7 -7 sheep 70 

### a11 causss fcr th2 pars i ~13 thr~u~h 1185 sre :oi~er :b,an for ti12 years 1965 througn 1972. A;~hougnhe acknowledged that he had 

### no data on the percantage of lamb 1oss2s attributable to coyotzs, 

### Mr. Roger Pearson, Secretary of the South Gakota ge~art~ent of Agriculture

### , contended :ha; i

### t was !ogica! to attribute increased lamb 

### losses sinc? 1372 to predators.3 percen: in 1073 and 1975. 

### 21saaya was ;ol:~c~ed and ccmp;ied E;/ 

### the Texas Crop and Livestock R~por~lng Service and, with the excsptjon of the 

### daca for 1967, is also cant2ined in Gze, et a:. G2e, e: a:. repo'r;ed lamb losses inT2xas 

### ra predators as a percentage of larncs born totaled 11.3

### r !nt in 137? of which 5.3percznt of iambs born



### -. . were lost ;o ~3~0~2s. niic3rresponds c:os21y with the 1i.dpercan1 of lambs born lcs; 1s predators as reported by the T2xas 

### CTOD and Livestock Reporting Service. Alehougn lambs 

### last to predators as

l- a percent oilimbsbdrn as reported by the aalsCrop and Liveitsck Reporting Service totaled 3 Fercenr in7373, ;lr. iir~auer reviiea tbij

-. . 

### - ri yri. upwari n3 11.0 Fercent baszdcn da:. csn:ri~ed :7 iexas Sheep i~d Goat OearS Losses and Xarkeiing ?ractices (1372) ~nl USOA SRS data on larno crops iar the years 1567 and 1371-78. Hr. litrauer made a similar.ca!cu?atian and derived larib losses as a prcent of lambs born of 12.3 percenx in 1976, 3.2 percent in 1977 and 11.9 Fercen: in 1978. The losses of adult sheep as a percent of scock sheep ore year or eider on ?and 

### is of Jan~ary 1 

### as reported by 

### che Texas Crc? and Livestock Reporting Service totaled 1.9percent in 1367, 3.1 percelt in 1971

### , 1.i percent in 1972 and 2.4 perceni in 1973 and 1.7 7ercent in72

f 1573. Ihese fi$ur?s ?re centzined in See, et a?

## . 2nd at-5 :3 be cor;ar?d,
1di:h ;ne $23 rzoor~ea aduit sheep 13s; :J ?rsdascrs in i3xas 2s 2.3 serz?nr of STGC~ sheep in 1374.. 17, The Wyoming Crop and Livestock Reporting Servics has colizcr2d and reported data on the perc~nt of lambs docked lost to coyotos sincc 1965. This data as compiled by Mr. Littauer sh~s a loss 

### rate ranging frorn 3.31 percent in 1968 to 

### 6.C3 percdnt in 1372, increasing to.8.23 ?erca-f,in 1973 and 9.29 percznt in 1974. Gee, es al. reporr, lamb losses 

### to 7rea3cor-s as a ?erc2nt of lamos born of 11.7perc?n: in 1974, of which 9.3 percent were to coyores. 3ased on a pub1ication, 'Jyoming AgficulturalTtatistics, Gee, 2t ai,re7orr. lambs 10s; to predators'as a perc2nt oflambs born torallng 5.5 7ercent in 1966,

percenr. in ?971

### , 7.9 percenc in 1972, iO percent in 

### 9:: ano 10.8 I percent in 1975. Xyoning USDA 

### SRS data showed lamb 10853s 

### ro :cyot?s
as 

### a percentage of lambs docked totaling 9.i3 perc2nt in 

### !975, 3.2 percznt in 1976, 7

## .? 0 PerconT in 1377, 7.07 7ercent in 1978 and 11.03 percent in 1979. Adult sheep lost to predatars as 

### a percent of stack sheep on hand 

### as ofJanuary 1 of 2ach year as reported by the State Reporting Service and the Wyoming Crop and Livestock Reporting Servicl
were 2.3 percent in1966, 1.6 percent in 1968, 2.3 percent 

### n 1569, 2.2 percent in 1970, 1.7percent in 1971, 1.8 percent in 1972, 2.9 percent in 1973and 2.8 percent in 1975. The comparable Gse, eta1


### . figure for 1974 was 3.5 percent.13 ;4r, iaryy 3g~rr?~, 3fT~~IC- ^. ~C'/ST?.r;i2n3n ,--= ,21 

### .l'S IZf 

### ,!;e
t4-/GRl , ng =am ?breau Fe~eriticn, a i~xer ~31~7: ssi3ner ~f ti8 

### ,>ijczir~ Pepar'xen: of Agriculture and a witness fcr Ai3i, przparod a cable oisheep and lambs lost to all causes in Wyoming for che years 1971 through and includiog 1980 from data cbrained 

### ircn the ',4yorning Crop and Livestock 2eborting 

### Service. Oividing tctai reporred losj2s during the 10-year 2eriod of 

### ?,9 1,300 by the cumula~i~/e inven~ary during :ha; oeriod of 

### :S,CdS. 00, he arrived atan average 

### . loss rare of 14.26 percent. ,Ac:arding ro Hr. 3ourrei, these losses
were calculat2d in exactly the same manner as tam1 1oss2s l,ver4 calc~lated by Cain, 2t al., wh!ch had arrived 

### atan 3l.3 9er:eni aver392 toral loss rats in Qyoming far the 2eriod 135G-79. Comparing this rate with the 7.3percrnt averat;? l~ss rste in Wyoming for the period 

### 1940-19,iajn, et 21, had concjuded 3.2: loss raws had 10; signifjcantly changed during ;fie ;eriod wneo 1080 was used. By contrast, 

### Yr. Bourret's calculations indicated that an approximace 6 gercen: increase in the istal average sheep and lambs losr. during the period 1971

### -80 ar an approxjmate 71 percent increase in total losses during tha gericd. 19. The inventory figures used by Mr. Bourret to nake the calculations referred 

### to in the preceding finding were based on stock sheep on hand as of January 

### 1 of each year. This stock sheep inventory is exclusive of sheep and lambs on feed and 

### Mr. Bourret used these,\It-. j~~rrex'j c2lc~la:i2ns a;so jncl~ced $re-co~kifis lCS~~S 53 1am58

i

l .7 

### as r@por~ed by ~ne :<ycningCrqp and Lir~eszsck 2e~orf: n.; Servics,vni i-? Cain Cornittee data was linixd loss2s 

### to iambs aftsr docking. 

### Mr. Bourret iscorrect that Cai

### n, eta1

## . used s-cock sheep inl/entory 

### thus excluding sheep on feed. Itis not clzar whether sheep on feed wer2 excluded from the total inventory becaus2 fha-c was ;he only dam available or becaus2 Cain, e-c al. consider2a tnat pr2daxion and other 1osses 10such shee? wouid be ninima?


## . 82 that as it nay, if the calcula~ions made by i4r. 3ourret are adjus~zd so 

### as t3 inclgde sheep on f2ed inthe-inventory and to excl~de pre-docking losses, the average loss rat2 for all causes for the period 1971-SC is reduced to 8.32 percent rather than xhe 14.2 percznt cziicula:?b ~y 

### Mr. Bourret. 

### 20. Mr. 3ourret sumarizsd the percentage of che January 1 sheep inventory loss 

### tocoyoxes as furnished by the Wyoming Crop and Livestock Reporting Service for the years 1965 througn 1980, with the exception of 1967 for ~hich data were no^ available. Tkss percentages range

### ,from a 1ow of .86 percent in 1968 and 1971

### , to 

### a high of 2.18 percent in 1976 averaging 1.29 percent over the 16-year period. The percentage of 1 ambs born lost 

### to coyotes ranse from a low of 3.10 percent in 1963 to 

### a high of 11.04 percent in 1979, averaging 5.53 percent over the 16-year period, In 1980, 6.5 percentc3yo12s lere 

### 25.8 perceni of tstal losses. 27. Or, Llarwin llielsen,Prof2ssor of Economics 

### atUt~h St2te Qnl,srxj:y, the Nielsen involved ic the lielsen-Curie study cfx2d in Cain, 

### et a!., and 

### a witness for.the AFBF, completed a i~udy 

### of the charactsrissics 3f sheep ranchers rsportiog high ?redaci~n ;ossss 2nd ihcse a2crrina 10:v ?radarion lasses in 1377. Baied on Gee, ec a1


### ., Dr. .li.isen concluded thar high 10sir3nchers experienced Iosi2s of docked idmbs to predation of 3 percent or more, wnile low loss ranchers e,xoeriencsd preda~ion lasses of 3 percent or 12s~.

### Dr. ?lie1 sen '3 study is refsrred
io in 

### Gee, 

### ex a1


## . and included pr-d~cersfrcm Colorado, idzho, klevlda, Oregon, Utah and 'Ayorning. 3a:a gatered &as for the period 

### 1571-71 and showed chat high loss ranchers had lamb losi2s af 7.0 ?ercenr in 1971, 10.0 percent in 1972, 12.5 percsnt in 1373 and 

### I4 percsnt in 1974. 

### Low loss ranchers had lamb losses of 2.2 percent in 1971, 

### 1.0 percent 

### in 1972, 4.7 percent in 1373 and 3.8 perc2nt in 1974. 

### Dr. biielsen cancluded that this data indicated 

### a substantial increase in predacion losses since 1972. The personal 

### interview survey was conducted in 1975 and ultimately required 37 high loss producers and 29 low loss producers 

### to estimate 

### or recall predacion losses for the preceding four. years. He acknowledged that 

### he could have constructed 

### a sample of low loss ranchers experiencing no predation losses, that he did not know whether the ranchers involved had 

### records of losses for those ;IP~P-~and :hat th2 Survey was csndbct?d 6fZ2r d-,? ban gn Ccnzound 

### 1280

the survey was concycr?d in 1975, 

### ;rdi~iiiary daza icir <22c yezr indicatzd t>hdt16 percent of high loss ranchers reportsd incrcassd predation lcss~s for that year, 62 percent reported lower ?redation losses and 22 percent reportsd no cnange in losses for that par. From this itmight be concluded that :oss?s wer? decrpas'ng 

### i,,rom 1974 to 1975. 22. The study "The 2concnics of Shesp Prodacion in Scuchwes~srn ]:an" atx2mp~2d

### to verify predation 1~SS~S 

### on can ranches having rsnge flocks in sau;hweste?n Utzh durlncj zhe period 1972-75. ihji sxdy indica~sd that 

### tne predation loss rate of lambs in 1375 was lass chan half of that prevailing in 1972. !-as: or missing animals 1,4hos2
carcasses were never locatzd w2re appar~ntly attributed :a 7reda:crs and other causes in fhe same propor~ion as verified 1ossss. Though he did not dispute the figures reported, Dr. Plielsen questioned whether the area could be considered representative of the Stace of Utah or of the 

### 17

### western states. 23. Statistical data frcm USCA and Utah indicatz that combined sheep and docked lamb 

### losses to a71 causes for the years 1931 

### to and including 1980 have fluctuated in a relatively narrow range, varying from a low of 8.2 percent in 1966 

### to a high of 13.75 percent in 1975, decreasing to 8.6 percent in 1979 and 9 percent in 1380.sheep flocks in Utah. Tile study (tias primarily con.cerned :virn she econornics of farm flock production, was conducted by psrzonal inhrvi

### ~w and included a sample of producers having from lG0 

### to,500 brzading 2wes. Coyotes were r~pcrt2d to have accountsd for 5.6 percent of the annual .iamb crop ioss?s, including pre-docking losses, and 1.4~er~2?t 3i adul

### t ewes 

# -

I C 25. Dr. Clair E. lerri:?, 

### a retired Aninal Scientist ~orrneriy snplayed by 3/ 

### - the U.S. Depar~nent ofAgricul

### tuxand 

### a witness in this proczeding, pres~n ted data purpo~c2dl y s howing a dramaxic incrlzse in 7r24ati

### cn loss rarsan snecp and lambs sinca 1Y2and the ban on Scnpound 

### 13G. Dr. T2rrill appeared 

### ta ac~ribut? 

### alnost ,he entir? r3duc~'on in sheep inven~ory from the 57 nillion in 194 LC 30 nlllion in 

### iS5C to I i' przdation. He developed an index 

### ta det2mine trznds and losses

. - using percentages 

### of death2 of lmbs minus percentages of deaths of sheep as report2d inUSCA s statistics showing inveniaries on hand


### as of January 1 

### of each year and deaths from all caus3s f3r the years 1940 to 1980. 

### He found that this index was highly reiatsd co predation 

### losses as reported in data compiled by the U.S. Forest Service. His calculations are based 

### on the theory thac ltdnen predator losses are increasing, the percentage of lamb deaths increases 

### faster than the percentage of sheep deaths. 

### He concluded that lamb and sheep deaths from predation acount for a much 

### greater percentage of

3/ Although 

### Dr. Terrill stated at the hearing that he represented the Aiierican Society of Animal Science 12 not::c GT ~thii bppearance oy that organization 

### has been made in the proceeding.

### xza1 losses ehan befor? 1372. Accgrding t3 

### Dr. Tlrril

### I,

-7 cverall Ian5 losses t2 ar-ecazicn 2s 2 22rcont 3f 

### lssszs 21,

7. .4-7,. caus2s 

### were /2 

### ;srtsnx in 1970, 80 ;erc?nL in IYIL, 73 percent in 1974, 84 perc2nt in 1977 and 82 ?ercsnr in 1580. Likewise, he concluded that losses of shee? 

### to predators 3s a percent of losses to a11 causes <r/ere21 yercent.in 1970, 27 percent in 1972, 30 percent in 1976, 38 percsnt in I977 and 33 perent in 1980. 2e acknowledged tha: prdation 1oss oerczntages decreased in the 1at2 1970'8, i .2., 1975 through 1980, lcrnich isconsist2n~ 'wi:h other evidence inche record. Because the evidence establishes that cnly
amsmall perc2ntage of sheep pr3ducors incur heavy predation 1csses

### , Dr. Terrill's zstimates ofpredation losses 

### as a percznta52 GPcotal losses are too high and 

### ?,reno; accepczd. 26. Hr. Gc~glzs 'lurfi2ld, Statistician in Charge ofthe T3xas Crap and 

## - Livestock Rep0rt.ing Service and a l~i mess for che !exas 12?~arr,rnent of Agriculture, submitted testimony to rhe effect that predation upon the Tzxas sheep and goat indus~ry has been continuously escalating since 1967. 

### His testimony was based on surveys of Texas sheep and goat producers conducted by the Service in 1968 and 1979, which ref12cted losses incurred by producers in the pr3ceding years. Losses of sheep and lamb5 to predators to~aled 172,300 out of an inventory of 4,802,000 sheep and lambs in 1967 for a loss rate of 3.5 percent as compared to 241,000 

### out of any inventory ofpredaiors anounted to 25 3erceni of ail 10sjei incsrrea, ~~hll? prxaaicn

, losses had rjion ro 58 percenT 07 losses 

### to all causes in 1973. He further testified that coyotes were responsible for 21sercent of ai1 sheep and lamb losses in 1978. According io Mr. ~Yurfisld', ;he oredarion ~GSS rar2 for iambs Was 

### 4.5 perceni gi :ne iamb crco (includes losses befor. and 3itsr docking) in 

### ;967,3.7 ;ercent ir-~ 1973, 12.9 percenz in 1374, 12.5percent in 1975, 13.5 Ferc2nx in 1976 and 16.6 cercent in 19i8. These loss rates 3rs baszd 

### sn the specia1 death 

### loss surveys conduczad by :he Texas.Crop and ii vestock Repor~i ng iervice in 1368, conducted by nai1ed q~ei t!onria?r., 

# - r and upon infor7a;icn a5 to losjes sarnered by the ,ex25 ~rop dnd Livestack Report: ng Servic2 

### as ?ar: of ii~ ncr~al yezrly 

## : nsient:r;/
2nd tot21 loss surveys. 27. Itwill be noted rhat the loss rates repor~ed by 

### Xr. Muriield isr the years 1972 through 1978 do no: agree a th chose calculated by by 

### Mr. Littauer (finding 16) for the years 1972 through 1373, tnose reported by 

### Mr. Nurfield being consistently iigner. 3ecause both 

### the Li ttauer and khirfield data are based upon lamb losses before and af;er docking the reason for the divergence in loss races is 

### cot apparent. Acceptance of

### Mr. Murfield's loss rates, however, requires theconclusion ma; a1;housn unknc~n csus2s cf sne?? and 7259 ~P~YS arn~uric2d

### to 18 ?ercenc oiall losses in,1367, ~nkncwnC~LIS~S of deachs were only 7 ?ercent of all losses in i973. 

### 23, A1though the loss figures reported by Mr. ,Vurfield included lambs born during the year which were lost to predators, the loss rates wer2 not calculated by zdding the 1,ambcrop -for the year in question 

### to the inventory 

### as of January 1. Hr. Nurfiela befmded rhis result, rejecting the idea that ;he lamb crop during the year should be added to the January 1 inventory in order 

### to calculate the percentage of predation loss25, because, int:r alia, the invenxory


### as o-iJanuary 1 of eSch year inc1uded 1ambsm born since October 1 of 

### the preceding year and add'ng the lamb crop would resulc in dup1.ication. Itappears, h~we\/er, that lamb crcp for each year as reported by SRS includes lambs born frcm October l of the gr2~2ding year thrcugh Segtomber 30 of che succeeding 

### year. Accordingly, ;he duplication referred ta by 

### Nr. Murfield does 

### not appear to be real


## . A table produc2d by Defenders reflects the percent of sheep and lamb losszs 

### co a17 causes inTexas as a percent of the January 1 inventory plus the lamb crop for each year from 1962 and including 1981 as reported by the SRS and the Crop Reporting Board of the 

### U.S. Departnent of Agriculture. The table reflects that car~bined losses 

### to all causes were 10.4 percent in,1960, 9.7 percent in 1967, 7.3 percent in 1974 and 6.6 percent in 1981. This table is in accordlost 

### 102,800 animals (sheep and lambsj :o pregators in 1381. Considering 

### a January 1, 1981 shep inventory of 2,360,000 2nd 1981 lamb crop.of 1,250,000, this results in a predztor loss razz 

### f~r shesp of a~prnxirnately 3 perc2nt and a predator loss rat? of lambs in 1981 of 

### app~~ximar21y 3.7 percsnt. 29. Dr. gale A. 'rlade, E;ct;nsion ',iiIdiife special is^, Texaj Agricultural Extension Service,.

### a former animal dzma~e 

### control agent for tne Fish and Wi1dli

### feSeryice- of U.S. Departmenx of Inr2rior and a ~,di tness for Yyorning, ec al., made a 1iczracure raview ofbat3 

### zn or2iation in ;he western United Staxs. He concluded thac 

### pr2cisz 33ta on losses of livestock to preda~ion werz avaiiabl? only from 

### szlxc?d farms and ranches, bur that 3s:imaxes suggesrsd that losses to coyot2s
were approximately 4 percent 

### to 8 percont of lan~s and 1.5 percent 

### to 2 

### percent of shes produced in the 17western states. This c-taappears in Counci1 for Agri

### cu!tural Science and Technology, Special Pub1ication No. 10 (March 1982), authored by 

### Dr. Wade and in evid2nce, but its
source appears 

### to be 

### a Oepartnent of the Interior publication not 

### 4



### / 

## - in evidence. Predation loss data compiled by 

### Dr. Wade appears 

### to

41 This pub1ication "Predator Dmage In The West: A Study of 

### coyoreicfanagement A1ternatives" (USD

### I, 1978), was identified as F'AS ixh 3 

## - and proffered as an exhibit. i

### he proffer was withdraw, however, upon obje,:ti 275 :ba:: +h2 ;a~th~:-s l.+,>~? ,s': :',ai 1st;:-3 fo:- :ro?r -c,<irvf ,-;i',jdo Wyoming, et a1, subsequently moved that 

### the pub1icaticn be 

### abmiitzd into evidence, arguing thae itwas entitled 

### to be admitted without a sponsoring witness. FWS offered 

### to

### make sponsoring witnesses available, however, xhe proff2r was again withdrawn.being uslrf. 20. Dr. Yaurico She1tgn (finding 6), noczd the wide var'sty 3f predztj

### on 

### loss estimates and asserted that thos? who yearn for a sing?? accurate and dependable figure for such losses wee bound to be disappointed, 

### because 

# - such an objective could never be realized. He testified thac he wide ;lariation in eszimates of losses due r,o predation could rzasonably be sxplained by: (1) coyox? densi

### :y ; (2) number of sheep 

### (crsoa~s) involved; (3) Jressnce cfccntr31 efforts; (4) s2ason of the year; (3) age of przy ~ninals;

### (6) a1ternative fcod sources 

### or grey species; (7) animal XanaTexenr protection; and (8)methods of collecting 2nd axpressing prdation 

## :asses. i-te further tastiiieu chat only rarely is predation observed and 

### thus several aiternatives exisred for deternining 2nd ex?ressing such losses. He 1is~~d these as recording aspredation losses: 

### (1) only those observed; (2) thos? verified as predator kills bas2d


### on appropriate diagnostic techniques; (3) extrapolating on a percentage basis frcm tho52 verified as predator losses tg 

### a lar~er popularion; (4) including a11 missing animals 

### as predator ki11s; (5) producer estimates fro^ interviews; and (6) producer estimates from nai1ed surveys. 

### He was of the opinion that producer estimatss of loss2s ' 

### came closer 

### to the 

### true situation existing inthe induscry than most efforts at research verification.9egartxct's

### Animal lanacjo Cm~roi Stzby Advisory Csmi:se in 1977 and 

### a 

### w~tness far Cefmd2rs of !di1dlifeya; a1


### ., submiZed testimony 

### to the effect that surveys conductad by mail questionnairss, 

### Gee, et a1

## . in particular-, subscancially overestinated losses to predators. He ~oi ntsd 3ut that they2 was 

### a 2aucity of

### rzijab12 

### dzta on che extznr of predation losses ta sheep prior co 1372 and maintained 

### that publicity surrounding th? 

### Gee, 2t al. sarvey 2nd the emotional clirnacs surrounding the predator control issue, biased reported pr?tiat'on lgss figures ucltrard. 32. 

### Dr. Cr2ndy fashioned 

### a cab12 ccmparing Sield studies 

### on szlxzive r3nges in 'Ayc~!~;,Idaho, Utzh and )levada curi

### ng years ?ncsrrpassing 'he 1974 rssul,$s :-e,"crfed.by 

### Gee, 

### ?ta1

## . in field cr biological st~cies, I investigators 

### xake an sfforc 

### tc find the carcasses of all dezd aniriai: and verify the 

### causz of deazh. Obt/iously, ~LIC~ stsdies 3re labor intensive, very ?xpensive, depend sn the cccperation of the ranckrs
or producers conc2rned and 

### can only cov2r a limited 

### area or number of herds. This, of 

### course, means that such studies 3rz sinpiy indications of what is happening and cannot 5e vie1:ied 

### as representative of losses inc~rrei by greaEer numbers of flacks, ?roduczrs in large
areas or in scates as a whole. Moreover, despite extensive searches,


### some animals are simply missing and the cause cf loss or death cannot be dstermined. It

### should also be pointed out that extensiye human 

### activfty inconnection wi €it searches for dead and mlssiny 

### animals, might inand ofitself be a factor reducing predation, , belgt,., c,lc,hat it.:~ouid ce ; 

### n the abs2nce 

### of 3tich activity. 

### Dr. Grandy


### -. . . acknow?ebsed ;hd', frcn ;i2:3 sil;di2s :;las inzdequzte to Y-> -F.P~: ; any proper jtacijtic~! analysis or cz!nci~sicn;. A 3-year study of five ranches in southern Wycming resulted in predation being confirmed as causing loss of 1.5 percent of lambs docked in 1973, 2.1 percent in 1974 and 3.2 percent in 1975. Corrosponding confimed ?,.re ?osses to predators were 0.2 per-cznt of 

### the inventory ineach of the three years which is 

### to be compared with 1974 losses reported by Gee of 11.7 ?ercsc of tke lambs born and 3.5 percent losses cfewes. A study of 3 bands of sheep inIdaho r2poced coniimed predation loss of lambs ta 

### be 1.3 percsnr of 1ambs born in 1973, 

### 1.7 percent in 1974 and 1.2 Jercznc in 1975. Ewe loss2s as 

### a ;2rc:nt of tcxal ewe invencory derz 1.6 perc~nt in 1373, 0.7percent in 19id and 0.3 percenc in 1975. An "adjust~d" predator 1oss rate ,das detemized by applying the ?erc?nt,Age verified predation losses bore to total losses and appiying This percentage 

### to missing animals. This resulted in lamb losses being 3.1 percent of 1

### ambs born in 19i3, 3-3percent in 197c and 1.3 percent in 1975. Adjusted ewe losses were 2.3 percent, i.3 percznt and 0.8 percent, respectively, for each of 

### the three years. These loss ratss are 

### to be compared with 

### a predation 

## :ass rat? for Idaho of 

### 5.8 percent of lambs and 2.0 percent of sheep in 1974 reported by 

### Gee, 2t a7

## . 34. A study of 10 large sheep operations in Utah resulted in reported

. , ccnfi

### rm~d 1

### ;.ma ; gases ~LI

### pre;;ato?s- of-?.7 pe?ccerr*, of lambs docked- ir, 1972, 

### 1.5 percent in 1973, 2.6 percent in 1974 and 2 percent in 1975.I, 

### - Adji~s~d ;ant lasszs were 

### 7 2ercent cf iarnos doc~?a in 

### 1911, :.I ' "7 1 

### perc~nt in7373, 5.3percent in I 21%and 2.3 7ercen; in 1375. 3aca
on 

### we losses :ver? noc available. 3y conzrasz, Gee, es 31

## ., found Utah 

### predaxor lamb 

### losses of 72.9 percznt of '~ambsborn and ewe losses 

### to predators 3i

### 5.2 percent of the inventory as of January 1 in 1974. Another field of biological study appearing 

### on i)r. Grandy's table 

### is that of t7,tloinigratury sneep bands in ?levadz ldhich 

### were studied during the period 1373-1

### 97J. Repor~sd1osszs to predation 'dere 6.5 percent of lambs docked and 0.7 percznt of the ewe inventory for r,he ;/ear 7974. This is 

### to be cmpar3cf 1,qiti7 the 1amb 7ossss reported by 

### Ge,eta1

## . in Nevada in 

### 1974 as 30.4 percent of 1ambs born and ewe 1osses in that year of 11-7percsnt of 

### the January 1 stock sheep invcnrsry. 3ecausz the ianc 

### los:zs


# , LJ predators in Nevzda reported by Gee exczedecf 85 percenc ci i tacal lamb losszs, Dr. Grandy asszrtzd thar they could not be taken skeriausly.

., 35. Gee, et ai. prdacicn iamb loss 7ercentages wer? calcuiat~d on zne basis of lambs 

### born and thus included ?re-docking losses. This 

### was not true of the 'Ayoming, Utah and Nevada studizs referred ~o above and 

### shown in Table 

### 1 of Dr. Grandy's t2stirnony, as these studies based 

### the lamb count 

### on lambs docked. Gee, et a1


## ., however, also calsolat2d post-docking loss2s 

### to predators and ifpre-docking losses 

### are eliminated 

### the percentage of lamb 

### losses to predators for the cized 

### states are reduced 

### to 9.2 percent 

### for Wyoming, 11 percent for Utah and 14.8 

### percent for Nevada.36. !!r, Srandj also men:icrfd ;:ss;es 1~nder:rriZt9n 3y she "sh and i/? i~l if? '
pradator cgntrol. 3e rzf2rred 

### to a study of 2 band of range sheep under the control of herders inan area in California, during the period June 

### 8to September 29, 1976, where there had been no predator c~ntrol practiced for over nine years. The fact hat tr,e band was under the
care of herdevs 7,40u?dseem 

### to negats this as a nc control 

### st~dy. Reported verified lamb loss to predators was 6.3 7erc2nt and the tots1

-3 loss of ewes and 1ambs to 7redacors was 3.8 percent. I nis stody being of less than 4 months duratjon is, of course, very skcrx. ~Icr2ovzr, alrhough the researchers inthis study were confident 'hat they had found possibly 100 percent of the losses, <her$wzs apparen~iy an incorrect count at snearing

### , 1e2ding to the conclusion cRac veriiied 7osses exceeded by 53 the number 

### ~f animals cgunted [?robabiy, short atshipping.tine]. 37. ,4 "no control" study was concucced in 1974 and 1975 in Piew Nexico


### on fencea 1ambing operations 

### wishout herders. Tne losszs to ~rzdatj on in 1974were 15.6 percent of the 1ambs



### . No adul

### t sheso were lost ta 7radators. In 1375, 12.2 percent of the 

### Iarnos ?no G.9 Ferc2nc of adult sheep were killed by predators. Because adjoining ranchers intznsified prtdator control zfforts, the researchers recognizsi chat the "no control" goal was not entirely fulfi?led. Another study designed 

### tomeasure losses in,theabsence of predator control was cmduct2d en the Cook Ranch in Moncana. Sheep were run in fznc2d pastur2s and the loss rate of lambs 

### to predators amounted to 29.3 percznt. Dr. Grandy, , znd notzd that 

### sne icss rat2 declined substzntia'l;/ a~nderirnpmv?d

35 Included in

### Or. Grsndy's testimony 

### is a table shol~ing losses za poisonous plants and predators 07 sheep and goats grazed 

### on U.S. Forest Servica lands 

### ir~m 4940 

### to 1976. ihe table shows predation

. losses 2s a percent sr"anixals grazed during the period of 

### IG8C ?is2 ranged from a low of 0.79 percent in 130to a hign of 2.39 

### percent in 1972. L~ss5s jn :he ?cst-iG8C years as 3 percsnt cf 3nicais grazed vier? 2

### .OT percent in 1973, 2.60 percen?: in 1974, 2.i7 eerc2nc in 1975 and 7.88 pert~ntiin 1976. ihes2 loss ratzs 

### at-: basd on producer estiflaces of t9e cause of loss. Actual percent2ges of loss~s to pr2dators are spproximat2ly one-half of losses in the table, because the number grazed includes only adults (a ewe 3r nanny with 

### a lcmb 

### or kid bei3g countzd asone), while gredation

<? \ losses include lambs and kids. 

### As indicated ?re\/iously(finding

# -, itshould, 07 course, be rernenber~dthat these fi2ures incIu62 only 

### the 

### summer grazing season, ldnich averages 2 1/2 to 3 nonths per yelr, chat lambing has ~sually been conpleted ?rior 

### ta irovenent onco 

### Forest Service lands and that predation loss?s in ldintzr and early spring may be substantial. The tab12 shows predatian 

### as a percent of total losses ranging from a low of 37 percent in each af the 

### years 1951

### , 1952 and 1953, to

### a hign of 64 perc5nt ini975. 39,. Because 

### he concluded that SRS invent~ry and total loss data published by the 

### USDA (wit.hol.rt. attmpting to assign 

### a csiuse for loss) were 

### the2 3 mcst t??iabi?, 3r. Grandy cons2r~cfsC 3 ~2~12 jn~;qins act lanb



### - 7 7

## - 3 -,.--, Ycss~s r3 2, I c2uses for the 13'tq?Si?rI jCaL25 =~r tne yzari 15c~-19;1 and 1272 

### to and inc:uding 1381. Averase ioss2s 

### ts a11 causes for ;he 1960-71 period wer? dotemined to be 8.3 percznc of he Jan~ary 1 inventory plus the lamb crop and 9.3 percant for the period 1972-81.

I He concluded that there was esszntially no change in losses to a11
causes over tile 22-y2ar period and no change in total losses dur'ng the 12-year period 1960 to 1971,when 1080 was used and during the

-, 10years following the suspension of 1C83. i

### ne resill t cnanses,

. .. however, 1T lamb loss~s ar2 sqaratzd frmshe?? losses and lanb deaths are calculat& as 

### a percmtage of :he lamb crop using S2S data. Thesz ca!cu.laticns result in an average lanb loss cf 10.4 percent during the years 1960 to 1971

### , wni1e the average for :he perioa 1972 

### to 1981 years is 12.3 percent. Sheep dezths as a percsnrage of the inventory as of January 1 cfeach year average 7.3 perc2nt during the years 1960 to and including 1971 and 6.9 percent during the period

. 1972Ao and including 1981


## . 40, Dr. Frederic Wagner, Associate Dean of the College of Nat~ral Resources and girector of the Ecology Center atUtah State University, a nembor of 

### the Cain Committee in 1971 and a witness for the National Wildlife Federation, testified that higher sheep loss ratos of recent years, which appear 

### to be real, are merely the culmination of a trend beginning in the 1950's. Although his written testimony refers to predation loss ratss, he made itclear 

### that he was actually referring30 

# - ,-+- reduc~i zn i 

### n 1osses ir;iii~di atel;; fcl1-,win~ I733 ~?lay nav2 Seen axri

## -

. ,,.-- ?- starxin.; 

### ;n ;Y:Z-~ lamb 

### ;oiies ~382 st2zdiIy du~ln~' ih2 period sf 1080 use, and continued To rise frxn thre? co fiveyears after the suspension of 

### lO80 in 1972. %enorad that losses appear 

### to have declined by from three 

### to six percent in the past four or five years. 43. Dr. Zcoert Robel, a Professor of Environmental 3iology ac Kansas Stace University and a witness for Sefender's of 'iiildlifz., eT a1


### ., testifi2d thaz in 1935-76 he supervised a study which focus2a cn sheep losses co premiers and olther C~US~S in a nine-coun~ area 

### oi south central Kansas. The producers rak'ng part in the sccciy nad SO percent of the shee? in the nine-cocnty di?3, constizuring 21 percent of the sheep in Kansas. Although the primary pLr7ose of this study was 

### to evalua:e the effecti\fenesiof various nusbarfary ?rac;ices in reducing predation, the study reported losses 

### zo all causes were 6.8 percent of the 

### sheep and 7.9 percent of the lambs 

### on an annual basis. proportion at^ cjuses of lanb deaths prior io cocking included lambing complications 74.6 percent, dogs 0.7 percent and coyotes 5.1 percent. Proportionate causes ofpost-docking lamb losses included disease, weather, unkno~in and other causes totaling 79.9 percent, ;vhile predation losses were coyotes 14.9 percent and dogs 2.1 percent. Annual Icssesto predators were 0.9 percent of the stock sheep inventory and 0.9 percent of the lambs born. Of losses to gredators, coyot~s ki1led 

## -- . 1J. , ;~rcs.~i ti? ;he zl-,e2pand ai3.o p2,-;2nr of int: iamci

## . UG~S KI ;lea 24.9 percent of 

### the sheep and 19.4 percent of the 1ambs

## . These resul~sand 3.8 perc2nc cf In? iqvenrory J; s-? shse? on -2nd 

### as c5 danuary 

### ; lost 

### to predators in Kansas in 1374 :e;or;ed by Gee, 2r a?


### . Only a small 7ercentage of the dead sheep and lambs were actually necropsied 

### to determine the cause of death. Dr. Xccel, nevertheless, expressed confidence in the accuracy of 

### the study, because cooperating ranchers reported their 1asses on a nonth'ly basls, thus r3d~ci il3 re1ijnce on the prcducer's nemory. Aithou~h i: is 1ikely that Kansas has a 2/ 

### - larger coyote population ihan in>/sther sta.3 ..&, ltiith possible exception of Texas, :he 

### !ow ?redaiisn rites 

### are attributa31e in paryta the fact that nost :beep are main~zin2dir fanflocks ;vhich enhanc2s insnacenent przctic.5, such as 2enning at

. . , night, to rebcce or mn;:s?;e predation. Anoiher lossible r2aian ;s <hatmost lambing in Kansas ot;xrs in tne fall,when 

### r,he fcoa 

### II pressures 

### on coyores are inininlized due to ',be f2ct 3ac ;!ips are born in the spring.
SC. 

### Or. John Schaub, an Econornisc, Chief oi

### ihe Ppst Control aranih, Economic Research Service, USOA, and a ritness far OSZA, submitted testimony on Lends in sheep, lamb and calf lcsses. 32sed cn an examination of USDA SRS data 

### on sheep and lamb inventorler, birch8 2nd losses for the period 1961 througn 1081, ha concluded that there was
an increase in lamb losses 

### to all causes after the suspension of 1030

5/ This is based 

### on an annual coyote harvest or take during the 

### - ,,??--

. 1a77 - ap,j 1q;Q 1f ,,,F inn

. lnn

, (a2 c$a 

# ;.-1l7a zn? ~5,?@i 

# '. ?qegl,

. ,- for exceeding the estimated total 

### take of approximately 70,000 for the States of Idaho, Montana, Nevada and Wyoming in 1977 and 1978, these states being considered 

### to have relatively high coyote populations.7 Arizcna, Idaho and 12xas. He %st';'i?d 

### thzc i: was. nor sossibiz 

### to identify the proporticn of loss caused by ccyote ?redation. 

### A similar analysis conducted for sheep losses showed the percent of sheep lost to all causzs increased after the suspension of 1080 in Caliiornia, ?{or-h Dakota, Montana, Nebraska and New ~Uexic~. In 

# - Arizona, Orsgon, Sou~h Dakozs and ;exas there 

### was a s~aeisticaiiy significant 

### decr2asz in sheep losses and no ita~isticaliy sisnificant change in losses in Colorado, Idaho, Kansas, Nevada, Utah and dyoming 45. As part afa sqecial- 1980 meaz anixals cost of production silrvey, conducted inthe spring of 1981 by personal inxrviews ;~ich 323 randomly selected sheep ?roduc2rs, data on loss2s of lancs and sneeg by 

### cause, including przdators, were also collec~ed. The result of this survey indica~ea thac predatcrs were r2sponsibie for apprcximate1y 61 percenz of

### the losses 

### to all causes of post-docked lambs, 

### while coyotes werE responsible for approximately 43 percmt of such losszs. Losses to a11 causes totaled 10.39 percznt of the lamb crop, with coyotes being res?onsible for 4.35 perc2nt 3f loss2s 

### to all causes. Comparing such estimated losses with the 35 yercent of estinatcd lamb losses to coyotes report2d by 

### Gee, et a1


## . for 1974, 

### Dr. Schaub concluded that the two surveys may indicate that the percentage of lambs lost 

### tocoyotes has increased. The 1980 survey, however, was confined to post docking losses and if, the comparison ismade using 1974 data on losses ofpost-docked lambs as reported2y 322, sz 31

### . , i CSS~S 50 ~3~3~25 l~f!-z ,:./ST 

### 53 ,:erc?n: 3f 

## : zss2s :3 21

### : 6i - 

## -8 causes in 137J. ,ni s csmoarison ltvoulc,of cours2, Indicatz cna: ioss?j 

### to coyotes were decreasing ratcer thzn incressing. According to 

### the 1980 survey, toral losses of stock sheep-to all causes constitu-ced 10.22 percent of the January 1 inven~ory with coyotes being responsibie for loss of 1.52 percent of the inventory or lJ.9 Fercent of total losses. In cznpariscn, 

### the 1971 survey as repor~ed by Ges, et a1


## . showed that total 1oss2s 07 scock shes? co all causes consti~uied 10.4 pe!*cent of 

### the January 1 inventory and that coyotes were res~onsible for the loss of 2.5 percenr 

### of that inventory 

### or :pprcxiiii::el j 24 percent of total lossss. This asain would ind'cate losses 

### 24 stock sheep to cayoxss have declined 3s 

### a perc5ncage of losszs co a71
causes.

. 6. 1esti;nony as predation losses incurred by ~roduczrs cr for~er sheep pr~ducers in Colorado, Idaho, Ncntana 2nd Wycrning is

### ir.cne record. The highes~ races of losses 

### to predators, chiefly coyotzs,



### 6/ Although entitled "Lamb and Sheep Losses 

### In The 17Westgrn Staces

### ," the 1%0 USDA study referred ro apparently re1ied 

### on data collected from only 13 western st3tes, the States of North Dakota and Kansas, which had been included in the Gee, 

### ex al. results f9r 1974, being omitted from the 1980 survey. A table ?repared by Defenders compares the 1974 Gee, 

### at a1
, results wich the 1980 data aft2r subtracting inventory and loss figurgs from these two states. Thi

### s subtraction, however, does not significantly change 

### the percentage losses caused by coyotes bear to losses 

### to all causes nor the percentage losses caussd by predators bear 

### to losses to all causes.

### - I 

### _-
, r ;I ' 

### ,2rrtj d Snyder, 

### a '.ior-!j~oc, L,S1orsd~ ,?urejr?j jheep,pr~duc-r 2nd 3 witness for 

### cI-;e 52 -=--;=: ,.-LL~ ,ed t>~t l~s;?~ 

### to lambs during the period o? bi~th through 

### szlz I,vere 2 percent in i972, 20 percent in 1974, 22 percent in 1975, 27 percent in 1975 2nd approximately 30 percent in 1978. These losses ar2 in terns of percent of lambs born. Losses in 7975 and 1976 ivere all to coyotzs.

1 > He staied thar. 13i~ 

### rec~ild~ during the jurrxer -.oni.hs ner? zaintained by 

### a nan and his wifp who looked aftsr the she?? and chat because :he sheep were in fmced paszlires, ir:

### as ;jossij??to IOCZ'L~ qeariy all ehe kii

### Is. iiis ciirreni: przdation rats was sca12d to be 10 17ercen; of sheep and lambs a~d 1 percznt 

### to guord dogs. :?s acxribut2d the reduction in loss razes 

### to the use of guard dogs, flnczs and us? of 2 helicopter in aerial hunxjng ~f ccyo:?s. 37. Nr. 4. K. Siddoway, a large migratary jh~ap cperassr frcn 

### ST. ,J,nthony, Idaho and a witnzss for Wyoming

### , eia1


## ., tescified ;hat he and iis
sons have suf-?red high oredator losses, in one year losing about 600 lambs from a total of 9,000 

### to 10,000 or approximately 

### 5 to 6 percent. 

### He further testified that ihe highest percentage of losses from docking to shearing was due to disxise and that 30 to 

### 40 perc2nt of losses from shearing 

### to the time the sheep are trailed 

### to sumer range wer2 due to predation. He stated that ~ost of the weak or sick lambs had been "weeded out" by the time the sheep are on the surraer range and that 90 percent of losses durfng the sumer were due to predation. 

### He acknowledged that he hadn't kept good records 

### on losses to all causes and that for every lamb lost 

### to coyotes, there might beI -5
C 0 3- 2 w a, -0 0 C --I FU VI * Ill ct 3 -2. -r a CA (D I3 (D 7 a, rt 2. 0 3 V1 3- m (D u I PJ 3 n S m -5 -h

I 0 3 0 3 0, 2. a " i-l 0 2 0 7 a, a 0 5-03 Ill (D r+ U (D

10 0 V, m ln 3 c+ 7 PJ Ct 

### -.- rD

A 7 cr0 CS 

# - 0 0 3 -43 0 C 3 (1

-_1 C> 03 0 i rU Ub
-1 2. 7 ul &- t c UI m Ll

2. 3 3 A. UI Fu 7 (0 0,

-A. I) 'it IS' 1 U (Il LlJ -5 d <i

2 IL> (>I 0

- U) " 3- -1. U)in 7

### 381

## . 3ecausz hs did no: have 

### rxcrss of 1

### ams born or sockzd,

on 

### the open range. He statxi that they converxed to a pirtial shed lambing pera at ion in 1980, wherein approxirnat~!ly 50 perc~nt of 

### the ewes 

### were shed lambed. 

### He further stared that in 1281 extre~ely

1 \ high coyore losses nerini~rrec! \,then

### one ionch old shed laabs &Here turned onto the 

### summer range. In one nonth coyoc2s ki!i?d 79 of 590 lambs. He tsstified chat predator losscs der9 due 

### ro zoyo~2s excep: for an occasional 5e3r. A?though hi: writtzn szatsneni is 

### t~ the effect that;they have not suffer2d any iasses rso 2agies'in 15years, hebtestified cha-;.in 1982 

### tc the date ofthe hearing 

### 1C6 lambs wer?

I -, iillzd by e3g1ss and 73 by coyot2s. 

### :na cnly ;os; recgrds zaintained by I;?. Pzpoulas are losses co predac3r;. kie 3ttrlbuced the Icw 

### lcss?s '1 I 

### j

# ' irl 79g0 c3 fhe fact_<ha5trappers fsuna f~~r or five coyoi? dens 'n the fall of 1979.

- .' 50, Mr. Nic!~ Theos, 

### a she<? rancher fron ~cleeker,

### Caloraao and a :.ritn?ss for 'Ayoming, ?ta1


## ., testified that his losses to predation had been steadily increasing ever since 1972, the year 1380 was banned. He testified that prior to 1972when he was running approximately 4,000 lambs and 3,000 ewes, his losses to lambs numbered approximately 120 or 3 percent and his 

### losses 

### to ewes numbered approximatsly 60 or 2 percent. 

### He further testified that in 1981 when he was running virtually the same number 

### of sheep (4,200 lambs and 3,100 ewes) ?redatio~i losses reac;;ed an al; cine higl~, totaling 13 percenc of idnos7- 07 lamo i3552s bec:.resn sirtn and docking and ~zites zo a:-,zmpz XI diagncse causes of death or keep recgrds oxer cnan ;r?datsr losses. 51. 

### ?4r.Michael Devlin, a sheep and cattle r2ncher 7rom Terry, flonxana,
a 

### member of the Montana Legislature and 

### a witness for Wyoming, 

### et a1

## ., subrnitted a table showing that lamb losses.

### to ccyotes ranged 

### frcm a 

### low oT 2.0 

### perc3nt in 1971 

### to a high of 14.5percsnt j~ 

# - -7 1976, declining 

### to 4.3 Fercznt in id13 and rising to 

### 3.6gercsnt in 1381. Atthe hearing, i.tdeveloped that zhis table included only 

### losses ofblack-iacgd lambs to cgyctes. 

### 51r. Cevlin ?x?lained that
was becsusz the black-faced iamos 

### zre consid2r~d z3 be :he ash 

### - crop, while all or a por~i3n 

### of the whi12-facsd lambs muid be 

### k?t

z L=rre91

### acbrnents


### . He acknowledsed

### , hckever, -hat the <\ti:- -,?- and black-faceo lambs ?/ererun in ihe sdme pastures 2nd silbj,?/c; :3 che i 

### same predacion, dij2ase, weather and other problems. if wh;

# -.-

d+ faced lambs are added 

### to the total, the percentage 07 ;ambs 70s.; 

### t~ coyotes in 1975 isreduced from 12.2 percenr t3 11.9 percent, the percentage lost to coyotes in I976 is reduced from 14.5 percent 

### to 12.7 percznt and the percsntage of 

### lambs. lost to c3yocss in 1377 is 

### reduced from 12.5 percent 

### to 12percent. During the la-year period from 1968 

### to and including 1381

### , Mr. Devlin ke?t records of 

### losses to other than predators inonly five of those years, because 

### he stzted that the biggest percentage ofdeath losses through the years-1 

### - is 

### frc~ coyotas. I

### nz TCI,T~:C~ZGlosses :3 czyo~es are gnl/ ,nos?

the carcass and verified th3 czus? ofdeath. Secause the bodizs of
some missing lambs ?re never found, Mr. Devlin testified that it
was quits possibl~! that his predation losses wzrz even high~r
t I than his recards indicatzd. '52. fir. Edward 3. S~zi~h, a sheep and cattle rancher frcm Cagmar, Mon~ana,

### a ,'Jcnzan? 5x2Senacor and a witness for ',~iycrni ng 

### , 3t a: 

## ., testified that in 1975 he so:d his entir? flock of sheep zft3r

, losing 96 of 

### 500 1am3s to coyotos, nearly 3 2'3 percenr loss. ?2

further testified t5at from the time Ccnpound 1080 oaic staticns lwer: 7laczd on his -3nch in 11247~ntii zhe use 07 1

### OSC Ittias sanned in 1972, he aid not 135s a sing12 lamb To 9reda:;on. :+esza'sd that his losses of lambs to coyoces ([,ere iOpercznt ;n 1373. Smith acknowledged that he maintained no records ~f caus2s of losses of lambs and ;ha;. the foregoing loss percenxges 'filere f:-zn memory. 53.' 

### Mr. Joe T. Helle, a sheep and cattle rancher fron Dillon, Montana, subnitt~d a table showing the total lamb losses between docking and shipping in 

### the fa11 were 

### 5:8percent in 1967, 12.2 percent in 1974, 19.1 percent in 1975, 14.2 percent in 1976, 12.8 percent in 1977 and 8.1 percgnt in 1981


## . He attriouted the increase in losses after 1972 to predation, inparticular coyotes, and the increas? in coyote

. . 

# - -7 

### -. , SVLZ :i ?? :c 7ng 335 nn ;:e 

### us? cf ':c;-ilpo.,r,a I

## ,;a. ,7j:nc;gr, EL 22~1 

### ri22 that herders kept records of.predac~r losses 

### on sumer ranges, he

### a cGyoce wculd be either mt~n by the coyote or would "celt dcwn" within 

### cwo days. 54. iclr. Chase Hibbard, a fourth gzneration sheep and catt1s rancher frorn Helena, Montana and a witness for AF3F, t~stified that the family ranch was best suit2d f3r she? and has hisiarically besn a sheep ranch. He stated thac in 1969 they Idere running 3,3GC swes and iost 3 ierc2nt 

### of the lamb crop betxeen dockjng in ezrly June and 

### shi?piqg in late September. Ouring the nex; flve years losses rose from 14 percsnt in 1971 XI 33 percent in 1973 and 35 perc2nt in 1373. ?e acknowis!d~ed+sat ihese wer? 

### totz! 1osses anc caac ic dotili be vsry di

### "=. I ,cult 

### to ~stirnate the loss r2t2 att~i5utabi 2 t3 coyole przdation, He asserzed, however, that he ;vas artributing the xaj'cricy of the losses to predators, chisf7y coyotes

### , and that when the numbers jump from 5 percent in 

### 1970 to 39 percent in 1973, s~mething was happening other ",an deaths 

### to natural causes. He asser~~il -,hat the oniy way they were able 

### to survive was by switcning frcrn sheeo to cattle and

I thac in 1975 they sald most of the rerna'ining commercial sheep. 55. 

### Mr. Truman Julian, 

### a sheep rancher from Kemerer, Wyoming and 

### a witness for Wyoming, eta1

## ., began kee~i ng loss records in 1975 shortly after joining his father's sheep ranch. He testified that in 1977 they lost 700 lambs or 24 percent of the herd and in 1981 they 10s: 635 lambs
or 10 percent of 

### the herd. 

### Herd figures are based on the numbers of lambs docked. He asserted that 477 or 68 percent of the 700 lainbs 

### lost in 1977 were lost 

### to predators. He testified that the 477 I535 lambs lcst 

### to all causes ii7 I%;, ?j",ima:ing 131 lmos
were 10s: to predators in that year. He staEzd that he knew coyoc? losses Idere very ?owin the period prior 

### to 1972 \;/hen 1080 was in use, losses being approximately 2 to 3 percent.

C ,- 

## - 30. 

### l4r. Leo Iass, a sheeg and cattl

### e rancher frsm 3uf5alo7'~iyorninq and 

### a 1d-itness for ?,F3F, testified that they were experiencing lore and mors 1osses frcm coyote preda~ion and that 

### he was f3rc2d 

### to confine his sheep for three months of each year because of cayotes. 3y confinenent, h2 zeanc 

### a small pasturn. 3e further testified tha~ he sold land, )whichhe had P~cmescsadedin :ne 792G1 8, locaczd approximately 20 ~ilzs eas: af :he rancn in 1974 becaus? 

### he could not us2 itaf+,zr1972 because of pr2da:icn. 41~hough he apparently had daxs 

### on his lamb crop and on toral lzsses, he subrnittsd no figures on the perc~nt oflambs 1osx to coyores 2nd other predators. 57. 

### Mr. Marion Scott, a third g2n2ration rancher from Campbell County, Wyoming and a witness for ,AFYF, testified tha~ during the 25 years prior to 1972, sheep and calf losses to coyotes were minimal. He stated that in 1958, he acquired 

### a small flock of sheep (250 ewes) 

### to supplement the income from his cattle operation. Although his written testimony is

### to the effect that they had few problems with predators until 1974, he sold the 

### last of his sheep in 1972,d2ur;ht~r had 

### a szall fl3ck :1Z ewes) of ~iir.hr.-d jh.25 and that jhe


### was forced to sell in 1976 b~caus2 of 10ssei to ?redators, mos~1y coyotes. 58. ,Vr. Jw Nuckolls, a sheep and cattle rancher from Hulett, !liyoming and


### a witness for ,AFBF, testified thai in he :en 

### jars ?risr tc i98: bij loss2s had Seen li 

### ewes and sli~hzly 

### ever a tnousand he2d of ?mbs to coyotzs. He asserted that a thcusand head of73x5s amounted cs the lamb crop for one year. Se f3rther 

### tsszified That 

### he iost l i1

i lambs 

### ra coyotes in 1981. His heaviest losses ajpear -3 nave been in 1977, when he 1sst 164 or 16 Fercenx 3: hii lambs ts czyo~~s. fiowever, inccmparing figures of lamb and shee? 

### 1cs;es icczrr:c during the period 1972 co and including 1376 as lis~ed inan affidav:; executed by t4r. >luckolls ii: cannection with zn applicatjon for ;;he placement ofa 1080 bait station on his property, ii apcears tnar. his lamb lasses averaged about 4 percon: during the years ~encicnea and that he lost only five aduli sheep to coyotes during :ha: period. 59. 

### Hr. Don Meike, a sheep and cattle rancher from Kaycee, Uyoming, currently Chainan of the aoard of the National Woolgrowrs Associatlcrn and 

### a witness forWyoming, eta1


## ., testified tnat recurring kills of sheep and lambs were common on his ranch in the 1930's and 1940's. He stated that when toxicants were introduced inthe predator control program in the 1950's and 19601s,losses to predators

-(IJ -v .r I-) a x -I-' TI OJ t' L aJ m V) rtf w _TI

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# - 3 3 (3 m v w c- IT1 LryW mv3 r- a) -U .r- L C E n- o -r- U tn ti0 >, 0) U 5- A 3 w w -tJ 3 m [I, L fu TJ nl u 4- (I) nj -c I-' V1 rn LCW rd .r- w w3m v, 

## ?2 0omc,

I w'iLT3 0 f L aJom w L -LO w v c w a) .- w I

### E a) 

## 2 o a) > QL5 war -U 0 s, Oc,L t' OJ wL3m maw rd t' tn EWv, a, 0 V) 

# -

-r-- (u L -c, Z(d5 V r twt' a 

# - LW-U > 'a V) a) 4' .r 

# - L -C 01 in vr cvlm ooa P-- 0 '.- 01 I-!

J-) 'i- 1n rr3 v 0 E-- 2z Lz c .--Ewa a) m 0) cv 5. 'C SJ -V W rd W r >. 43 0 3.oU-a m aa w C z In ro 3 4 0 ul vrcw coo r V) 7 rd 'rcnO+ aao Q I-' -0 I7 'X 5- !J

- LII: (I) 3 f 0 1.7 0- ., , ,. sj:;ply missin2 at ch? 2;:~ 37 

### z;:? y2zr 3s~ ;;?I CZU;~

### 6Gt3i~-z~t

, , for th? catis2 of cnat loss. 61. ,Yr. John J. Yines, a jfisep and carzie rancner from Giilztze, 'tiyoning, Presidenz of the Campbell Coun-cy Predatory Associarion, and a l~i~ness ?or the Association, testified tha: there had been a decline in sheep numbers in Carnobe1i County frcm 11 9,i71 in 1372 to 37,822 in 1981


## . Ye at"~ibuted this deci

# 'ne 3rincipalx1y

### to ~redaticn problsms and ?crlac",d staiernenrs from ranchers who nad sicher gone cu: of ~h? sheep kusicess
or reduced tneir herds becausz of pr.tdaror problenls. je indicazed ?ha< he numbers of coyot2s in Camooei1 Counr;~have increas2d si nc2 1912,

1-- basing tnis 

### on the fact thas ooun~'es

### were ?z;d on an averase of I~C coyoIes 3~r ye?r inche s2ven years prscsaincj 1272, while that n~xber

-I I had increaszd t3 -SO1 for 

### 1976. l?e ,-,rti?er t2stifiea 

### mat :he nl;mber of 

### fox bount'es paid in Campbell County al)eraged 

### ;85;er year dur'ng the seven .year period prior 

### to 1972, but averaged 666 per y%r during the perjcd 1972 through 1976. ~lthou~h the table submitted wiih his tsstimony appears t3 shcw a decline in bounties paid for ioch coyotgs and ioxes after 1976, no bounties 

### on foxes were paid in 1978 and thereafter, bounties were paid only during the perjod April i through October of each year, because pric2s paid for furs were considered
a sufficient incentive 

### to hunt coyotes and foxes. An affidavit executed by Mr. Hi nes 

### on December 14, 1976, is to t5,e ef

### iect that he had no confirmed losses of sheep and lambs 

### to coyotzs during the years 1% 

### to and 

### ~nciuu~ny i975, tkac ne lost 6u lamos LO coyoces in 1976, 50 ofwhich were before docking, that 

### three coyotes were killed and that 

### to his knowledge. 

### he had no other [coyat?! kills during the balance of 1976., 52. +lr. Bartcn +i,artza,3iy3ctcr cf Fish and Nil,,? if? for t~? -27; ~~~~;~

. , t,..-' "' of New,Plex'ico 2nd 2 ';r; Tries: for 'Xycming

### , 2t 21

### . 

# .,, "7 r72cl 8 ;:hat 5assd
on contacz wi~n members of his iarniiy and o~her ssocknen in the Puebl

### o, both coyo~g numbers and predasion have increassd ivlmensei

### y in 

### the region-since cancellation of the use of 1080. He submitted the results of a survey of sheap producers in the Pueblo hich indicated that auring the ;eriod July 1 cnr~ugh Octaber 30, 1577 to pregators, chiefly coyotes, lambs

7 0 and 124 rams. AIt5ough he s~aced there 

### wer? a~proximazelyio,COO heads of shes? on the r2servation atthe tine ofthe hearing, inventory figures for 1977 were no; repor~d and i: 

### is 

### ns1 ?ossibl? to convert these loss fi~gres ta percentases. Fron aeszfigurgs, i: appears <ha; losses of adult sheep to przda~ors werg a~pr?xi,~az;y 90 ~erc3nt of loss2s of lambs. Elased an rlyorts from she?? produc.rs, 

### Yr. Martza scatsd triat predation losszs were gradually Sncreasing and that the numbers in the flocks were decreasing. He acknowledged, however, that the producers did not k22p any records. While he asserted that producers were mostly blaming predation for the decline in sheep numbers, he readily cgnceded they had ;roblens with overgrazing. From scent-post surveys and aerial observation, 

### he concluded that there were a lot of coyotes on the res2rvation. Issue l(b) 63. Cain, et 3.1. apparently had no data on losses of cattle 

### to predators and, in any event, made no reference thereto. The only survey data

\ in 

### the record as to cattle losses 

### topredators since 1972 is that in CAST Special Publication No. 10, authored by 

### Or. Wade (finding 29),' 7 1dh.jch j 5 :C'J r,h? ~3.ff2cc :?~i-, 3. ; SS~C?,~; 2; 32-:?:.S : ,I ~52 i

## , ::?~:f,-:: 7:/ 

### - stazes tiere i~ss ~3 ~re.dators. Stgtl'~~ic31 

### arzl2;i s iricijcea ;%I;;?

,

# - the te,szimony gf 3r. Jchn Schzub (finding 

### 44) shcws :ha; calr 1csses to predators have increas2d since 1972 in i3of 15 western staizs, only New Mexico and North Dako~asho:liing no ita<ijticailysisnifjcacz


## - manges. Individual ranchers from Colorado, 12xasand 'dyorning testified 

### as to ?redation lasses 

### to c~sile, chiefly cal\ies, zinc2 1972. 

### From this ces~incny itc~ul? 

### be inf2rred that przdztion ro caiztle was not a proble5i prior 

### to 1972. Coyozes dr2 ;he ?rincipal ?reda~or 

### on cattle, przying ,2n calves at birth or sbor-iy -hereafter

7- 

### 64. #r. Jim 2ar;on, 111,-a rancher frcm Sour, ,exas, !..iho w!:n his 

### family
owns and operaws CNO cattle ranches, and 3 wirnes: for Nycming, 2t a1


### ., testified rhzc pr'zr to 1372 losses ofcows and cll,/es :o prsdatars


### on the smaller ramp (S7ur Headquarters) were ainiiral. 

### He further I testified that Compound 1080 had bean used on the 5eadquzrter-s 2ancil unti1 

### the mid-7950's and that itwas used on neighboring ranches aiter that 

### time, creating a perimeter, lwhich coyotes seldom pe~etraced 

## . ;?e stated that in the winter of 1972-73, they lost about 36 calves and five CONS 

### to predators, chiefly coyotss. This amcunied 

### to 12.46 percent 

### c~f calves and 1.73percent of 

### cows. A table showing cattle losses on the Headquarters Ranch, attached 

### to his testinony, Snd'cates



### 7/ A document "Cattle and Calf Losses toPredators--Feeder Cattle Enterbises in the Llnited 

### States" bv C. Kerry Gee, at~blishino the resliltc of an industry survey in 1976 by the USDA and reporting losses for 1975, 

### was used 

### as a cross-examination exhibit, but is 

### not in the record.of tne herd. Mr. Barron tsstiiied tha; some calf loss25 artrj buced 

### to unknown causes, two in 1972 and three in 1973, were actually indirectly caused by predation, i.e., :he calves acquired scours from ihe praczici of penning heifers and cows 

### so protect them frcn coyotes. 

### 63. Confronxid wixh a tlble from Gee (1ot2 7, supra) dish a~oeared t3 show average ciitt12 

### IOSSES in ihe Scuibwest 3egisn, dhich incll~des Texas, subsantially-below those shown inhis table, Vr. 3arron responded thac neighooring rznchers were losing ihe same aaaunt and ;hat ranchers serejust beginning is realize the extsnt of losses ts coyotes. He siated that czlf losses :o coyotes 

### on :he lorger 05 his ranches (Tongue River) averaged 3 oercenc of ti2 calf crop from 1975 through 1981. Calf losses 

### to predators 

### on the smaller ranch have declined subs~antially, numbering six in 1980 and three in 1981,
or 1.79percent and 0.89 percent of the herd respec~ively.

### Ho cows
were lost 

### to predators in either of these years. Mr. Barron attributed the decline 

### to aerial hunting by the F#S, the use of M-44's, guard dogs and ground hunting of coyotes for their pelts. 66. 

### Mr. Dan Tracy (finding 48) submitted a table showing predator losses of calves of one each in the years 1973 and 1975, and two in 1974. 

### He had no losses ofcalves 

### to predators in 1976 and 1977. He did, however, 1os2 two c11 VBS 

### to predat~rs in 1978 and i981

### , three in 1979 and four in 1980.-. filie calv~s :3 CS~O'LBS 3nd has lost ar;? CLI ca;i2s fcr -,ha:

a 

## - reason evory 

### year since tha: Tim, %with tne 2xcep~ian cr 

### !982. Ye d.id nor 

### loss any calves to coyotes in 1982, because he adopted a seni-confinement calving aperation i

### n order to minimi

### z~prsadtion los$es. He staced that this substantially incraased costs fcr fsed and labor. Issue 1(2) 68. Cain, eta1

## . ~ade no rzferencs co losses of goats to pradatars. ,As


### we have seen (finding 

### 38), USaA Forgs~ Serv?c~ data ccmbir,es producsr reporrs of losses of sheep and goats co predawrs 2nd ?cijonous ?lanu. Losszs co preda~ors 3s a perzsric of animals SrlzZa iiirins the ~erj~a af 1020 use, ranged frzm 3 ~CW of 3.79 serc?n: In 1330 LO a nish ~7f 2.39 percent in 1972. Losses to predatsrs in the pos:-:i80 yzars
as a percent of ani~als grazed here 2.07 percent in 1973, 2.Npercont in 1974, 2.17 

### percent in 1975 and 1.88 percenc in 1976. decause che number of animals grazed does not include lambs and kids (a ewe and lamb or a nanny and kid being countd 

### as one), while ~OSS~S io predation does include lambs and kids, actual ?redation losses are approximately one-half of 

### the above percsntages. 69. The articleby 

### Dr. Shelton (finding 6) reflec~ed thac goat lossss to predators averaged 4.90 percent of inventory (sdulcs and kids) during<he five-year ?erioo 1567 through 1;7!, .rti;n zh? niqresc being 1C.37 g2rc2n~ in !27J and 

### :ne :olt,es: b?ing 2.1i ?erc?nT i'n 1369. igsses co all c~us2s ddr~qg cnis perica averaged 12.31 Jercenc of inventory and iossas co ?redators as a percent of all losszs averaged 40.79 percent, ranging from a nigh of 85.29 percenx in 1970 co a low of25.13 perc2nt in 1367. Beczuse kidding was ~!ss.sntial ly a confin--nenzoperation, thes2 are POST-~arkjng lossss 70. Catz on ,he precise umber 3f goacs i

### n the United 

### Stat2s 3re apcarently

f unavailablz. ,exas, however, has a greacor number of ;oaEs than any 

### orher stat2 (1,450,000) 

### as of January 1, 1982. Surveys by che Texas Crop and Livestock ,?e~orci nq Servi

### ce i ndica

### re chat srec?

### tors
were responsi5:e for the loss of 

### 45 percent oS all l~ss2s of Soats and kids in :267 and this had rii~n to 72 ~erc~nt ?n 1S73, 4x5 cgyoces being rs2;onsi51e for 24 2ercent of ail loss2s 3f soars 2nd :I kids. Itap$?ars, however, that przdator losses of goa:s in 1981 totaled 67,45'0 head or approximately 4.6 percenT of inventory. 71. The only rancher owning goats to testify Idas 

### ?4r. 

### i.Charle: Howard, Jr. of Meridian, Texas. He t2scifiec ;ha< he 

### sta:ptza qozz ?r:duc:ion

I I in 

### 1965 and bid not have any problems 1wi~k predators unti1 1973. 17e asserted that coyotes began killing his lamos, forcing him 13 8211 

### his small flock of sheep and that during 

### the period 1974 101973, he was losing approximately 40 goats per year out of a flock of 200 to predators. In 1977 and 1978, 

### Mr. Howard joined with a group of ranchers having predation probiems in hiring a privat2 trapper,
wnu removed approximately 53 coyotes per year rrm cne r;owarasl

### . ~! pastur2s and zdjaining areas. Thinkjng ?ha; the nur,ber of ::oyo:?s had 

### been reduced to th~ coj-; ;-2: 

### ;-!er.su]d s;(c-na, i-;j; .perzi--cn, he incre2sed his 

### soat herd ts 11OO he;d in 

### 1973. testifiad that as soon as nannies and kids ,Hers turned 

### sut 

### J? the shed, cojotas began kiliing them in the pastures. Xhen the goats were penned at night, coyotes would kill in the day~ine.3e stared hat because ofsevere predation losses inlarge orusny pasxures, he aas forcad
co confine hii goats to 3 130-acr? 

### ?asare by Cay and a :cur-acre srap at nigh^, ldhicn rssul:ed in 

### a savere sarasi:? crcblsn. 72. Mr. Howard lost 91 adult joacs t3 ioyctes in 

### i9i9 and an addiziona1 91 adults lost to parasites viere attributed to 2redarion caulsed by the necessity of penn'ng ihe goats at night or confining :hem to sinall pastures for protxtjon from csyoces. Out of a herd of 330 brseding nanni?s, 

### ~e comaliy could have oxpec7ed 3 cr3o af 2: least 240 kids. 3nly 27 survived, 

### kowever,and he eszimaczd thax predators killed 

### or other*~ise caused the loss of 213 kids or approxi- 

## - mately 89 percenr of the crop. 

### ihe remains of approximately onehalf of tnese were found, others being missing or sinply obliterated. As an example, he indicated that a hoof or an ear would be found. Intensive control measure;, including use ofthe toxic collar (findings 75

## - 79, infra), 

### were instituted and lasses ofadult goats declined 

### to 45 

### out of 

### 1500 head (approximately 3 percent) in 1980 to 32 out of 1830 (1.8percent) in 1981


## . Losses of kids to predators were 17 in1980 and 27 in 1981, 15 of which were attributed 

### to coyotes and 12 to raccoons or grey fax.73. The t~xic collzr crsnsists 3= 3 rirCcer reswr.ioirzgntainins'a :c~::ic 3/ 

### - liquid, in chis case a solution of 

### IC80, attached to he necks of sheep 

### or goats by straps. 

### Use of the toxic collar is based upon th2 principle that coyotes normally attack 

### shee~ and goats

-, by bicing the necks or ~hroats. ine iS22 is that in the course of 

### such an attack the cgllar woui~be aunctured and ihe csyots ~ould rocsive a lst3a1, sral dose of 

### 1C80. A?though ?unc:ure 3f ;he collar in this fashion resul~s in rsnoval zf che ofFznding coyote, the coyocs's a:tack 

### usually also results in the death of the sheep 

### or gcat t3 vdhich the co1

### Iar was at-cacned. 7. The toxic coilsr has been ?xt?nsil/sly testgd by.cke F:JS unc2r an
bt !>-4 d Llon experiinenta; usepermit and the 7,iS has mpiied far r",-4-rv'" of Ccuncouna 'I 

### 082 in zce ccxic zoliar. Fiela :?st8 cf the co? 

### :zrs


### - were conducted in Idano, 3ontan5, 12x2s and Alber~a, Canada, during the period June 7, 1978 to and including March 31

### , 1980. Of 28 field tgsts during chis period, 17were consider%! successf~l in that preoation eicner sxopped or declzned following use of the collars. Eleven tests wern U~SUCC~~S~U~ Sccause predation st~pped for unknown reasons or coyotes did not attack collared animals. Of 

### 52 attacks by coyotes on collared sheep during the period June through October 1978, 36 cr 69 percent of collars were punctured



### 8/ In addition to sodium fluoroacetate, field tests of the collar have 6een conducted using sodium cyanide and diphacinone as the toxicant So;j."m fl"oi-fiacetate has "-A- '-';"A"^-' -A"+ ",""^"F"l UCCll ClUJUUyCd lllU3 L 2ULLF23 1 ul lCdf""- 

### - -. La~~2s 3r 71~2 ?cisaced ccyotss ;vere found.

, , azcacks on co:iar?d sheao or 

### seats cur- ,ns :he 92riod Iiovember through fiarch of 1380, 30 collars 

### or 71 percent der? punctured. Secause coyotes were removed by ccnven~ional control techn-iqces


### on the test ranches or 

### on adjacent properties during cbe period of

### the tests, it

### is 

### not possible to aitribute the decline or cessation 

### of predation solely to the co'llars. It i; clear, however, that such a reducticn or cessaiion fnl:owing evidence of coyote a~~acks an coilar2d animals dnereby csl1ars -/ere punctur?d, consti

### tutes convincin~, if circznstani~al 

### , evidence of collar eife~tiveness;.,411 ~~sTs 37 collars 

### to dace have been in Penc& pasares. 75. Extensive tesis of the toxic collar on goati have been csnducied



### - at three separa-e sites on the L. C. Howard 

### Ranch, ?erldian, ;?xzs (finding 

### 71) beginning in lace duly 14i9. Atthe ii~xe, che ?o;varas
were losing one or ,Tare,Angora cjoats to coyotes eacn day, 12 coyore kills having 

### been verified as occarring in the week anding July 23, 1979. Upon the beginning of 

### :he rests 

### (Texas Test ?lo. 1) 

### , collars


### were placed 

### on 20 small kids. Collared kids were killed and collars punctured on thenights of July 27, Augusc 10, September 6, 12, 2; 

### (a collared kid killed and the collar missing, but probably aroien) and 22, Octocer 7, 22, 23 (thecollar missing but probably broken), January 11 and 25 and Febrlrary 22, 1080. Coyote predation declined markedly, 

### there being 

### three kt11s in ilovernber and one in DecemberI 3-7 ,. . . ? 1713, -hr5~ 1,;j3nl;ar:/, four Inr2gryary and one ;n Y~rcn ;lf :380. ,A1zhou~n 

### no ~o:sar,gdc2yo-es ,erefound, :: ,V;S CS~.C~:C~C L-~z.: LC least I3 coyoc2s were ?raca~!ykill?d as 3 r~su;; zf 7unct~r;ng collars. Becaus? 

### atleast 15 coyotzs 

### wer? taken by conventional
neans *xithin

### a five-mil? radius of the tssc sit2 during the same period, the reduction in predation could not be 2txributed solely tc
use of xhe coilar.

7

# - 10. During the period of 

### the czst referrsd co in c!.-1 orec3ding finding

8, at leasx one coyote avoiden- a he coll~r 5y attacking gcats Trrcrn tne
rear or flank, ki 11 ing one uncollared kid, one adultgoat and 240 callared goat: inOc"Lbbr, one co1lared goat i;n 'Icvmber "379, and two adu?

### t goats in February and one callarca kid in ;4arch 

### oP 1980. Aithougn chis point of attack iicharacteriitic 

### of CG~ liilii, dog kills were ruled ou~ because 3f cl2ar coyo~2 Cracks inthe vicinity 3f scme of the remains. OSv'ously, che collar is ine+fect;vc under such circumstances. 77. Tests at another site on the Howard Ranch (Texas Test No. 2) resulted in tn2 killing by cgyotes of one collared kid and a c~ilarld nanny 

### on August 19and anothzr collzred kid 

### on August 22, i973. 1 three collars were punctured and there was no further predation at this site into march 1980. While no dead coyotes were found, it
was concluded that 

### two or three were probably killed. Twelve coyotes were taken by conventional means within a five-mile radius of this site during the period lateAugust 1979 through May of 1980. This test was considered successful and especially noteworthyn 0 --I --1 P, 7 CD a cL) 0 a' r+ LA z 

## r;. CDaA. 2 _I m 

### e 0 3 >> C UJ C lA c-t IU W " IV P LU 3 a 1U cn
.A

d In -4 U3 .4 9, 3 a rl 2- m k m pl 7 vl -0 

### 3. 0 ^I rt 0
A ID Lo P, 3 a n 0 v 0 r+ n, 7.3 -I (D a a, rt 2. 0 3CJm ln a, 3 (n S 0 7 rt -2 << a, -11 r-t m 1 u7 0 m rl LA o', 0 0 LU n 7 (0 -0 a, Ln c- i C 1 ID in

-4 3- 2. LA in -1. rt 10 3- a, a 3 0 rt'am rn 3 C m n, CA -ti 0 7 a 0 iu c k ul -1, C3 7 u> fli < fD -3 LU c-t -3. fD -5 iD x nJ lA
(1. C 2 U CD 3 n ID 0 - li (> n f-l LU lf

1 .1 (3 3 LU --A (3 0 cr: 0 ri CL, IL r) c t 2. i A. L-k c:

A - _J
i 1 -3 IU hi 7 ID Lllin October, only one in November, cnree in 3ecmber 1979, on2 in January and PACin Harch of 1980. A1though 19 coyoces were taken by othermeans wiAhina five-mile radius of this sic?, chis zest
was considered successful, six coyotes beinS probably taksn by the collar, and the cnronologiczl record of collar punctures by t lyotzs,

, providing convincing, Ir circurns~antial evidence, of the e?-f:cri veness of the collar. 80. Tests of the toxicco1lar in 1979 atzcocher rancn in Tzxas, wnicn had apparently suffePed heavy losses of goat; to foxes and coyoces,
were unsuccessiul, bec2952 ?r?dstion 

### zlzsed or declin?d for unaetsmined rezsons and 

### no aztacks on coi:ared ?ivestock occurrgd. 

### At Idaho Test SireNo. 

### 2, coyot2s killsd 14percznt of lambs kecqeen docking and marksting in 1978. ioss2s <he previous year werz approximately 50 9ercent great2r. Toxic collars were used ceg'nning in June and nine collars were punctured during July and Augusi 1975. At least 2ight coyotes were considered to 

### have been killed,

C although no dead coyotes here ,curid. Dredation declined markedly, there being only two kills in September and five in October 1978. Three more collars were punctured one in December 1978, one in June 1979 and one in August 1979. There 

### were two kills in November and December 1978, none during the period January through Apri1 1379,9 four in /*lay,

### ihr~n indune, TNO eacn in Jl~iy and Adgust, four in

. , -n3n I -r 

### Sepienzer, si~ni 10 3::oter 3ni tiir?r! in ::~\~S.TEBT ,. re coocerarin: rancher a;?ribu:.d 13wer 

### ~redziion lcsses :n IS72 

### to successful use of the collar in

### 1973. 'iihile circunstant~a? evidence was considered to support this conclusion, other forns of predator control employed concurrently precluded unequivocal adoption thereof. 41. T2~ij of i1Aoocher sixs in Idzho in :he 

### summer of 

### I978 Save no

C r infonation 

### as to collar er-recziveress because pr3ble.n coyoTes Nere apparenzly removed by other Jeans and collared an!~alsvere noi attacked. Like the 

### tests on che Idaho sic? referred 

### to in the preceding finding, tests of the collar 

### at,Xcntana Tisc 

### Yo. 1 were conxinued from 1578. Predation itspoed iron i~te izptembet 1j73 throu~h Apri 1 of 

### 1971 after two c3ljars were ?unct;rec by ccyotes in September of

### 1978. A1though callars were reinzroduced in 13 t2 Hay of 1979, after five lambs were killed and again inJune aixr three more lambs were killed, no collared lamb was attacked and the only puncture of a collar was attribu~ed 

### to wire. 3ifficuity of targe~ing aztacks to collared sheep was attributed 

### to the presence ata distance of about one-half mile of a flock not 

### involvea in 

### the test.3

### 6 

## - 92. Alberta :?st No. 1 !was Scgun 

### sn 3 

### skse? rznch in Carss:cq, Ai:er~a, af~?r six coycc2s 

### ki'led abcuc 

### 15 she29 in 2;rly Ccxber of 

### 1275. :line young ewes wighing zgproxixazoiy 100 7cunds each hero csllared and placed in an 80-acre pasture cn October 19. On Oc-cober 23, six collared ewes were killed along with three Sucks in a nearby field. Four 

### oi the ewes were bit~en below the co1lars and thus 

### the collars
were not 7unctured. One colla.f*&as 7unctured and one collar das missing

### , but appeared co have been punctured. ?lo f~rr2er przdzzjcn occurr2d atthis site through Yarch of ?Sag, ai~hougn csystes continued to frequent zhe 

### ama. This test was liszsd 3.5 a~?zrently succ~ssfv1 

### , notxithstanding the fact,eislit csyotss :ver2 she: in the vicinity of the t2st sit2 in Octcber of 1973, becausz these cgyot2s
werz apparen~:yk11;ed priar to Octo~er 23. The fac; :?at c~yoczs I,vere able to Si

### es the rhroats of sheep ~,ii:hout punc~uring sc;me of the collars emphasized the need for larger collars on :arge she2p. 53. The Texas Agricuiiural Ex?erinent Station applied for and was granted (May 1980) an expl rimencai use pernit (E'LIP) icr testing of 1080 in 

### the toxic collar for the control of coyotes. ~nitialiy for
a period of 

### cne year, the EUP has been ex~ended and the tests aro presently scheduled to end in Deczmber of 1982. During the period August 1980 through December 31 

### , 1981

### , collars were deployed on 

### 10 ranches (including the Howard Ranch, Meridian

### , Texas), 

### 69 col1ared animals were killed or zttacked by coyotes cr dogs and 33 collars
were punctured. A total of 116 uncollared animals were attackedr. 

### or killed in targec ?astures. ~7.42 coyores and one dag were found,

, .. vnich were corsiaered t3 53~3 SEZ~ ,ii:1?d

# " ,?uncrjr*q~ I:axic 01 as. 'laricus :argscinq srrategios were iesr3xl,ih? nozt effective being collaring ail animals in 

### a tarzez flsck or coi!aricg



### -t all small animals (iambs or kids) within the tarsst flock. Ine latter strategy appeared 

### ta be effective atmost sicer. Ineffec~iveness of collars was attribu~ed chiefly to difficuities in dirscting attacks iOcollired animals. Coyotes were taken :y convenrional means 

### on the test sites or 

### on adjaceni prg?er;i?s and ail instances 

### of apparent iuccess afthe collar i

### n reducing or elioinatiog oredation could not be atiributed sailely 

### to ~he collar. 

### 8c. Toxic collars have also been tested by t;?e !{ex klexico Oeparmnent of 

# -1 Agriculture in 1381 under an exgerirentzi use ,prmi 

### t. Inese ces:s wer? conductad by ranchers uhc were qua!!i.iei as cer~ifizd applica~ors and isiued 

### approxima:ely ton collars each. 3scauie of an inadequaxe number of collars, problems with managing sneep so as co direct coyote attacks 

### to collared animals and failure of cayotes 

### to puncture the collars 

### atleast five of six tescs were unsuccesif~l



### .

## -

. . ,q:pine, ie;(as, ipj,entor of :he taxi: coilar aod 2 ?wirnessfor Tb? Taxi

### -Ccli.r Comeany, emphasized ihe sel2c;lvi ty 5f the ~31 i 3r and i;j ability ro remove depredating coyoces wnich could not be taken by conventional techniques


## . H2 testified that the on1

### y experienc2 required for successful use of the collar was recognition of the circumstances where i

### t bwou1,dwork. :+ehad conducted t2s

### ts of the

?? 

## - collar under the FWS experiment21 Qsepenit sn 13jites in iexas in 1978, nine 

### of wnich 

### were i~c~~ssful. Ye acknowledged tbt hh eiid bjased the results in favor of success by rejecting aro~os~d sits,
e.g

## ., sporadic ki11iiglover a wid? area, ,wererhecollar ;vas nor

.

# - 1ikely 

### to 1,vork. 

### He s;ated that li I coyote was kil ling consistently in a 1ocalized area, use of the callar Idas more 

### Ii:el y -2 be successf31. 85. 

### Mr. McSride testifi~d 

### rhaito his knowledge, the collar nad COL beea tested under open range conditions and thai because of ;he difficulty of targeting attacks to coil~red 

### 1ivestock, the co11ar
was unlikely 

### iobe effective in 

### such situations. 

### He rejecred s~ggestions that coyotes seemed 

### to sense something d:ffer?nr ahout collared animals and thus declined to attack them, or moved elsewhere, asserting that coyotes had killed lambs wearing bells and 

### thai if it
was that easy to discourage coyote attacks, coyote predation would 

### not be a problem. He also rejected criticism that targeting coyotezttacks cn collared animals was inhumane, declaring that lambs ,&ere
c3yots punctured the c3l!;r, the cayot2 wzs 3150 kill2d. 87.. bong tne disadv-inxages of the toxic collar is the necesiity of sacrificing col1ared 1ivestock in order to 

### cernove pro01em 

### coyotes. Another disad)/antageis the labor involved in panning or renioving frarn 

### the arza of ant-ici?aiel cgyate attack uncgllared livestock so that ihe attack will most 7ikely be on callared aninals. Alio labor required to instal? 

### che ccllars, in checking and r2sei:ing :a1 iars which idve s1i;ped out of ?roper ?csi:ian, i.e., xhe llarnyx regjon immediazely below 

### the earscan be ex~ens:ive.A1thouqh ihese labor1 costs exceed tne cost of me c3llars ($15.50 to 516.75 ezch) and the cost sf sacrificial aninali, :ne collars 2r2 ice ZX;?I-IS~Y~:O insxal1 on 1 arge numbers c~f1

### i<ie~iock. 

### r cBri la ind: c5is1 ::at ii the ;ol!ars were 

### more *widelyused, the unjt ccsi could be reduced. Collars are, of course, ineffective against particular cayotes and other predators, which attack 1ivestock at other than throat areas and because of the dif:iculcy in taryeting attacks :o collared -animals, the collar does noc appear LO prcmise much hope of success

under range condicions.a.dcs?, l.tka1 

### to c~ni 3es, of tsxicant. Aifhcush Mcntafia (Ss;jari.~ent of Livestock)

### , South Dakota(Deparment of Agricultxr~) and Wyoming (Department of Agriculture) have applied for the registratior, of sodium,fluorcacetate in Siijs to controi co;yotzs, SLas using Ccmpound 1080 have noc been ?xt?nsively tasted in the Unitzd Sta~es.L3r;e quan-cities of sini1

### ar baiti, referred co as irop baizs, conzsinins strychnine were ~sed prior to 

### I972 far ~ke 

### ccntrsl of pr~datars, chiefly cc~yot?s. 89. Dr. James 'ii.Glosser; Stat? Ve~2rinarian, ACministrst;r of the Animal Health Division of the Montana 3eparmen~ of Liveszock and
a witness for Xycrning, etal., rs?or+zi on the us2 

### 27 1283 in SL3s
co suppress the pccula~i5n of sway dogs and ca;: on Guzm in 

### 1967 and thus contrgl an outbreak of rabies. 

### ,At the ci:ne of the first confirmed cases of rabies (:4arch 1967), the population of stray dogs and cats on the isiand was estimated to range fr,m 20,000 to 60,000. A program of capturing and vaccinating these animals was unsucc~ssfulas they easily escaped detection and capture in the dense jungle growth. A program involving the ?ick-up of stray ani?ais, shooting 

### of stray dogs and cats, and che 

### use of snares and traps
was begun in June 1967. These methods result2d in the removal of approximately 12,000 animals. Additional cases of rabies were confirmed in August of 1967 and it .was detemined that more drastic
means of reducing the population of stray dcgs and cats were required.u I

, Strychn:ne (;as cansiiord bux re:sc'-,& Secaus2 of jcs "-\ 

### '-.,; ' I II~~I "UA 1c1 ~JJ b

8. . 

# - c3 3?: 127 T~S 2nd ar::~~s and rr? pisk 

## - 2 s ; k 41pq3,77-= -djv -.- get4r1'
was -,rid krisfly but izs ~lse :.,as discon-,i?u?d, ber3hse i:'. 'NZS ineffective a;ainst cats, not sufficiently effgctive acjainst dogs, rquired too much time 

### to recrieve and resei and xas ex:rremely dangercus to humans; and Comgound 1080 in large meat-bai;i placed 

### atgarbage dumps was tried, but found wanting, because dogs were not lured OUT of the villages and the baits spoiled rapidly in

### Guam's climax. 90. A prcgram involving the us2 

### sf Cmyound iCaO in SLDs was inscitzred in 0c;ober 1967. Each one-ounce bait concainea 3.4 mg. ci

### ICSO. Baits were placed 

### at nisht and 

### on paper plats8 ac l2asc 2013 feet aparx inorder to minimize ihe possjbilixy of target saecies ccnsumlng more :ban one bzit 3nd :o facilitat2 rscriev31. Al 1 uneaten baits werz removed on a daily basis (by 

### 4 a.1.) in ~rder


## - to minimize risks to humans and non-target soecies. I

### he prigram continued for 15 months, with the period of most intmsive us? October thrcugh 

### Cecemcer 1967. Although only approxjnately onethird of the aninals considered t3 

### have been ~oisoned by 1C80 during this period were found, Dr. Glosier estimated the number of cats and dogs destroyed by 1080 during the October 

## - December 1967 period 

### at rougnly 6,000. Of 16,239 baits placed during the 15-month SLD program, 14,053 

### or 86.1 percent were taken. A total of 16,799 dogs and cacs were destrayed by all means in 1967, declining to 3,035 in 1968. Thisincludes only carcasszs '31 13~~2d 3y government ;?rscnr~l2nd is exclusive 

### oianixa? s zes~rgyed ?riva;sly or on ~i 1i c3ry reser<jaricns 1 There (wereno coniim,ed cases of rabies afxsr September 

### of 1967, 2nd other means of control were used csncurrently with 

### 1680. ,4lzhougn

. 

### he acknowl~dgedthat, depending 

### on whether the origjnal estiinates of the dog and 

### cat popuiation were on the high side, them could have been as many 

### as 25,000 dcgs and cats 

### on Guam )#henthe 7080 2rosram
was discontinued, 9r. Glosser considered the program a szccess, contsnding that he removal of an additional number of dogs 3nd cats lessened their density and stopsed animal-co-animal transinission 

### oirabies. There issvidence thaz stray dogs and car,z
are still considerzd a problem on Guam and that SL2s con~aining1080
were beirg used in che:r centrol as la",? as 2ecs,cer of 1975. 92. SLDs containing 1380 

### d5e c;rrently used for wolf and coyote control

I in 3rilish Columbia. For the la~zer cas2, 3 ~g. of 1C80 in 3 powder formulation are inserted inzo a~proximately 50 grams of bait material. A naximum of 12baits are placed at the site of 3 confir-ed coyot2 attack, that is, around 

### a livestock carcass or scanting station omal ally, however, only two 

### to four baits 

### are placed as the nurk~r 's limited 

### to the number of coyotes considered 

### to be causirig the problem. Baits are well spaced and buried under soil or snow 

### to minimize :he chances of more than one bait being eaten by the same coyote or the poisoning of non-target species. Of 108 baits placed in 1980 and 198i for coyote control, 64.8 percent were taken by coyotes, 3.7 percent by non-target species and the balance were retrieved by Ministry of
,Enviranrnenr 3ersonnel in accordanc2 ~.-/i :.;7 2s-3~; Iscea ?~-:C~~LT?S. in I~SC-~I, four 

### 1C8O ;aii sations ie1gn:ng acc~cx;ca;?,iy 3 kg. each :.celn?p?aced, of wnich id kg. or 36.3 T?rcenc 

### :er? consider~d
TO have 

### been consumed by coyotes. 

### Dr. Frank S. Tcmpa, Ministry Staff Specialist inCarnivore and Wildlifz Zanagement, and Coordinator of ?redator Control Programs, Ministry of Environment 

### , 3ritish Columbia and 

### a ~;ritness for Nyorning,, ota1


## ., considered the Csrnpound 1680 program to be as sdcc2ssiul 

### as other predatcr contro-i methods in rernovi~g wolves and csyotas graying c;n 1ivestock. Secause of regul~tions requiring bai

### :s to be retri2ved no nor? chan 14 days afterplacamen~,

### he acknowledged that ?h2rc wers cccasion5

-, when deprddaticn continued afkr

### the baits !Mere removed. Ine preaator control program in 3ricisn Columbia is rolativeiy small, Or. Tcmoa estimatsci that che number gf zoyo;es taxen r?ypreda:~r cmtrol personnel each year by all mechods nay 

### be 

### as low 

### as 1CC co 120, whilo the number takn annually for their pel~s was in :he ranse

93. SLDs impregnated with Compcund 1080 are currently usdfor dingo control inQueensland,Ausxrailia. aeef, horze or kangaroo meat is used 

### as bait and the minimum bait size is 125 grams. While preparation of the baits is apparently restricted 

### to government or authorized personnel 

### ,distribution of the bai

### is 

### (Iand or air) is by the landholder. The 1080 program is considered effective, its 

### use being credited with marked reductions in the numbers of "bitten" calves and an increase i 1ambing gercentaaes

. rornoo~~nd 1090 howver, ; s 31 z? 

### used in large baits and evidence in the record is 

### not sufficient 

### to enable evaluation of the effectiveness of these methods of 1080 delivery.

### - ,-c- drop-Sairls were piac2d by AGC ?~rscnnel of the 

### F%S in I:au, :hat ~lacemenzs increaszd tc appr2xi~az'y 922,CCO in 1964, decrsased zo approximatsly 345,000 in 1969 and incr3ased to approximately 821,000 in 1970-71. During this period, the placement of 1080 large-bait stations declined from 15,349 in IS60 r,3,11,3T3 in 1970. The'concurrent use of 1C80 1 arge-bai

### t statiens compl icates the 

### matter of det~nining he effectiveness af drop-~aits 95. Dr. Samuel L. Beasom, Associate Prof~ssor in tne '2epart~en;of !4i 1dlifeand ii sheri2s Scienczs atTexas ,A&:4 University and a witness for 

### the TexzS Department of Agriculture, perfamed a study in 1971 and 1972 to deternine 2ffec;s of przciation on 

### white--tai ied

7

3 -. deer popuia~jons.

. ine sxdy *as pe~fcrrn?dby acpiic2~ion or ~nt~ns've control techniques to remove predators frgm a 5,400 acr2 zrza of the King 2anch in S~uth Texas and corncaring the resulcs with a similar sized area without predator control approximately ,Fivemi12s distant. Specific control tschniques institutzd 

### on February 1 of each year and terminated on June 30 of 1371 and 1972, included steei traps, M-44's, strychnine neat-and-egg-baix and shooting 93th 

### at night and during the day. Approximately 2,000 strychnine trgated egg-baits were used in each of the two years and approximately 3,500 meat-bai

### ts were used in 1971 and 4,530 i

### n 1972. A total of 188 coyotes and 120 bobcats were removed frcm the experimental 

### area during the two-year period.



### . Strychnine drop-baits 

### were considered to



### . -- have been responsible for the removal of 

### 10 coyotes and two bobcats., ;~fiy-sji -. ccyoies >derecaken by y-dn's, which means :hat a?pr~xlmat?iy

, . conclu&d :ha; 2s

### jezc;.i71~ &l1 coyotes 2nd jcbcats had been rmo8;ed from the approximately nine-square-mil2 area. From aerial transects, itwas cietemined that tne fawn:doe ratio 

### on <he sxperiinental area
was 0.47 in 1971 and 0.82 in 1972, while rha~ in the controi 

### araa was 0.12 and 0.32, respectively. 

### Itwas cancl~ded that intensive predator 

### control could ~r=tly incrgase lwhi

### :e-ta.i 1ed deer derisities. 36. 

### Vr. Joseph 3. Gurba, Head of the Crgp Proc~ction 2nd ?sit Can~ro' 8ranch 3f the 4-1 berta 3epartnen: of Agricu1:?IT? and a 14 tness for Wyoming, et al. PresSflted a cab12 rhowing the nuncers aicyanide cartridges, strychnine cubes and 1480 bait jzacions used in :he

-1 Provi,~ce during :he per: od 195: t3 and incl~ding 

### 198C/31.
, ge

-3 -. tab12 rerlects :hat strycnnine cubes wer? rlrst ~s2d ic,Aloe-->?in 1953, chat 195,500 

### aisuch cubes $wereused in 

### 1355 and 

### rhat,;tne number has sincg steadily declined 

### to 3,240 in i980/81. Fifty 

### 1JSO meat-bait stations were piaced in 1351, the number incrcaslng 

### to 773 in 1957, declining 

### to zero in 1978 and numbering 14 in each of the years 1979/83 and 1980/81. 97. Hr. Gurba cnarac;eriznd ihe ,Albertajredaror control 7rogram as successful, explaining thae its object was not 

### to exterminate coyotes, but to rgduc? predator damage to tolerable levels. He attributed the success of the program, notwithstanding the steady decline in the number of 1080 meat-baic scaiions, 

### to the 

### use of strychnine drop-baits,cyanid? pns and chf hiring by the ?ravine? of 2i;hx pr2da;or c~nxr~1

,

r 8 ;?2c;alis; in 1372-73. (-2 

### a;s?rxzi 32' zcs: 123C ma:-bai:
, Ijrl~
wers placed in souzh*~es;ernAlbersz :;her? cnz-'hjrd cf ,h~ snesp production in the Prsvince was concentrz~e~ and which bad a hign level of coyotes. 

### He stated the 1080 stations >/ergan area conxrol program, while cyanide guns and strychine dmp-baits were us2d in
I L specific cases to take ki1ler coyotes. He estimated the 3vzrage number of coyotes taken annually by 3ach 1080 oair sxat:on, if ti.,? bait was ccmpletsly consumed, at30, zven tnough only 

### 20 coyotes considered to have keen poisoned by iC30 were found in the ias; fi~" years. 

### ,Yr.Gurba indicated chat <be nunber cfcoyate ?elcz mrk2ted annually in A1berta in rxmtyears ranged frcn 

### 27,COO to.35,COO, ;vhiie;he average nunber taken by 211i nethods ?.ch year in 552 predator control ?rzgrarn ranged from 

### 1,300to 

### 3,OCO over :ha lasx Tive years. 98. The Montana Oepzrt~ent of Livestock

### 's app1ica~ion for an mercenc ; exemption under Section 18 of the Act 

### so 

### as to permit the use of 

### 1080 in SLDs for zne control of de~redating coyot2s and feral dogs was filed under dat2 of July 24, 1981. The application envisaged ;he



### - placement of 3.6 rng. of 1080 in 15grams of bait material and ~nac a maximum of 25 baits would be placed on gach section. In Se~tenber of 1981, the Montana Department of Agriculture submitted a plan proposing 

### a field test ofSLDs in order to address questions of, inter alia, the attractiveness of such baits to all forms of

-3 h;':";if=. Inr p;iir~b~zcza Ln&cresearcn warn neeaea io assess tne521ectivizy cf silch hi ',< 

### to cayoxas under /aricuc aelivery cgnc!; c; 23s. Or. 

### GI,ss,r ('i ?<ins SG).39r.e~ ;nzc i res2ercz s,ij -:csjzjry ant t?s:~f?ed::at :he 3:3n )was in cb,? prccgss of 

### tel?~ ?armula,ed cr compieted. 99. Iinplementing the planned field rest, baits were placed cn :he surface, atelevations approximately 18" above tke ground and buried. Coyo~es accepszd 75 percznt of baits placed'on <he 

### surfacs, i8 percent of chose piaczd 3: 2levacions and 67 ?erc?nc of those 5ur:ed. After 25 days, apparently con-tar921 s?eci?s ?r?icmindn~lj :cc?!~tzd the baits. 3uring the initia: period of tne czsz, :her2 dere 5 substantial number o? site!visits by non-carget, s,zaii ,zammais. The53 tests werz conductzd using ihr~s or ar~racxants, bus ncc cox?cancs

### . 3r. 

### Glosser acknowledgzd :na: 

### 519s US& iii :?cnt.ana could not ha112 the 

### same degree 

### oi sartcy 2: -52 prss2n: as :./as

1 achieved in !Guam (nightly ar daily rezrisvai of unesten aa:ts zei95 irnpractica1) and that adaicional cescing and riork 

### ta mi n;mi ze .ccecrcanc? and hazards 

### ta non-targzcs was necessary. He insis

### tea, hcwever , tnzt sufficient data was available 

### to support reyistration becaus? of :he oral toxicity data on 1080, itr selectivity and th? 1ack 

### of documented instznc2s ofhuman deachs or i;lnesszs frain use of 1080 

### as


### a predacide. He indicated that some "finetuning" would be required


### as to dosage, placement, type of lure, 

### etc. tominimize non-target risks. He considered these to be judgment matters for those adrninistzring the program. 100. Testimony 

### on methods of application OFSLDs was given by Er. Major L. Boddicker, Extension Wildlife Specialist, 

### Departnent of Fishery

- and-~i id1ife Biology, Colorado State University, and a witness for--. . USDA. Acccrding to 

### Dr. aoddick~r, 2r~ic:znt,~lzc~~ent'cf SL2s and

, , placornent af baits 7~r trap us2 arl 

### idsnziczl. ze expiained thar effficient SL3 bajc placemenr in reia3icn co larse fezturos of tne landscape (macro location) is zhe same as for traps, that 

### is, along roads, streams and mountain features. He further explained that SLD bait piacernent was identical in.ra10c;tion to small features (micro locations) of 3 locality (cow chips, grass humccks: trai1 incersections)



### . Dr. Soddicker testified cLhat the carcass 1, i a dead horse, sheep Gr cow are often dsed as "drzwbzi~s" or sxcLians ta concentra~2 cayoce accivity inan area and incre~sz the ?robability chac the coyotes cou:d bc taksn by xechanical devices or 

### SL2s. He asserted chac baits can be fornulaced and tailcred to the season, animal food pr?ferenc2s, aninal behaviar, aninal size and capacizy to nold food. %edescribed a wide var'ety of lures which c?n be used to attracc an animal to a zrap, jnare or an SL3. He sta;?d chat the selectivity of lures and kai

### ts cculd be increased by choosing those nos! appealing to the target species and by placement, 

### east, coyotes preferring open feeding areas. 

### Cr, aoadicker described two instances of specific coyote ~redaticn ~roblems on Color?do r3nches

. where he considered that placement of SLDs containing 1080 in conjunction with appropriate lures would nave an excellent probability of providing either immediate relied or removing the offending coyotes within three days. Although Dr. soddicker did not advocate any specific 1ini

### t on the number of SLDs per square mile, townsnip or otnei- area, itis ODV~OUS thac 

### Re coniernplacks u;e of SLWs with 1080 will be extremely 1imited ("minor use" in his words) and only afterstudy ofthe ;arz-icular circ;msz3nc2s 2nd d2te~ina;icn 3y a ?rq.i;oc dl,-S: 3fla! '_,'?2,SJC~ iSf " 5 233?138r; fZ2. ,I 7,

## . Sz~3; CAZT 2$;j~"?f'~? <v' csnc2.ln~la:ed c,ov$ring scme 

### of ;>e SL3s 'ri75:7 fI;,c SXR~S 

### Sr oxher objects. Ee c~stified, hcwever

### , that 

### 2fficiency (coyoc? acceotance) l~ias reduced by approximately 40 percent 

### to 60 percmt over that of placing the baits 

### on elevated locations up 

### to23" above ground lsvel. 701. In 1981, the Fish and Wildlife Servic2 applied for an ex~erimental us2 permit in order "L ttest the effecti\ieness and selectj~~ity 

### of 1C80 in SLDs. A study 'Fieid Evzluazion 

### Of An An;if?rxil izy (Agent, Sti1bestrol 

### , For Innibi~ing Coy012 ?eprcduc~ion," in ?viaencs, conducted over 

### a five-year pericd (1,363through*i967) by the 3AS suggest2d tnac other carnivores, '~i ~h the possiole excepticn oS sklanks and fcxes, 

### sel

### :om ate indi\/idual bai'-:s irltend2d for ca:iotzs. This was a-,tributed +,o selec~i ve bai L placsrr;enc, e9e re1a:1~2;:4 small number of baits ger 

### square zi??and :he extended home rznge ofcoyotes. Coyotes, however were credited with taking only 22 percent cfthe baits. 

### [Mr. Roy McSride (findicg 35), an e~ployee af 

### the 

### FWS ac the tine, participated in the djstribucion of these baits in soucnwestern Texas. He considered that coyote acceptance of 

### the baits was Foor. A Plarcn I981 ?:cis reporc 

### on evaluation of baiting txhniques, using markers, i .e., radioactive or similar material rather than toxicants, with which Or. 

### Glosser. vras familiar, reflects difficulty i 

### n determining coyote and non-target acceptance of baits. Dr. Glosser pointed 

### out that the sample 

### size was not 

### satisfactory. This

### was 2pnarently duc 

### to the necessity of killinq


### or capturing particular 

### coyotes and 

### other animals that had consumed baits


### .., ?

### 92..Large+ai tssta~i ons 21-2 su5stanri 2 I ?or:icns of horsz, cor,lr or shee? meat inro which has been inj2cxd 2n zcqueous soi~cion of 1080. Injection 

### was by means of a syringe or meax su~p a<a concentration of 1.6 grams of 1080 per hundrgd pounds of meax. FWS, formerly Bur~au of Sporrs Fisheries and Wi1dl ife, presently Animal Damage Control Division, 

### po?icy 

### was that injections 

### be m'ade at evenly spaced inrervals of appl-oxinately four inches (whil. <he meat was jxi 11 warn inorder 

### to facilita~? even dist:ribution acd

-, avoid 

### hot spots. ine minimum r,umber of sta~ior;s rcquired to achieve effective management nomaliy were 

### to be olacod, not to exc2ed an average-of one per tiwnshi

### o, As indicated (fi nding 94)

### , 15,349 bait stations were plac2d in 

### 1960, 16,692 inI963 and 11,373 in 1370. Ail stztions (,./ere?laced dest of The 1COch meridian. Cain, et a1


## . concluded thatevidencs that the stations were off~ctive in 

## i1 reducing coyote predation 

### on livestock was lackin!. This conclusicn
was bas2d on 2videnc~- indica~ing that losses of sheep t3 a11 caus?s rernained constan: and t,:at there was no evidence of a significant decline in coyote populations. la3- Conpound 1080 impregnated in large meat-baits appears LO have first been used in the United States for the control of predators in the 

### winter of 1944-45. A 1948 article by Weldun Rcbinson, referred co in the testimony of Dr. Wagner (finding 4G) but not in evidence, reports on the experimental piacernent 

### of 1080 baits in Colorado, Nevada and Idaho in

### areas of several hundred square miles during the, 71 ,,di nj-2~~ 1944-.L5, 

### 194.5-45,?nd 

### 1345-47. -. ; 53 3i2i5~5 fyz,,,;zs concurrsntiy insimil?r ?i?caients Zrd had a;parznii~~ been ::red for seven ;~re\!icus 14;nsers

### . ieoar-.s 

### frmrzcchers ; ndic3:eci :ha: lamb losses were reduced by an averas? of 87 Jercsn;. 2ates ci predation loss suffered by ;he ranchers previous 29 these ex~erlrnents


### were not furnished.

, 104. 9. k'agner also rsferrzd 

### to 198: 2rticle iy Lyncn and :iasi (not in evidenca), ~hich ccmpiied infanation 

### on annual i3e.p and ;oat * 

### loss?^ to predation in nation,al foresis (Forest 5~rvica Zegjsns i-8) during the years 1960-78, and 

### on the annual number ci 

### ;;80 staiions used in the same areas during the period 1960-72. Carrelaring annual shee?-and-goat-?ass values :rith the annual number af lO8O jiaricns and finding then siaciszically sicniiicani, Lynch anc Uasi tsncl~ded
I that the 

### dec?inirrg number of 1080 s~ations was causally reiat2i to 1 increasing sheep and goat \asses. 3r. Uagner auesz:onea ~fie:a?r ;ni; correlation represented cause and effec~, srnphasiring that although lamb losses inthe early 1950's iol1owing the 

### introduction oi

### 7080 appeared 

### to be lower than inprerious 

### years; juch losies began rising in the mid-1950's and continued ts rise during the perjod 0 f 1080 

### use, peaking three co five years after the 1972 ban 

### on 1G80. 105. Being of the belief 

### that ~idesgread use 

### of 1080 large-bait itations


### was for the 

### purpose of suppressing rcgional coyote populations on the assumption tnat there was a relationship between coyote densities and predation, Dr. Uagner concluded that the eifec~iveness 

### of the use ofsheep 10~82~ over areas 9? this sizz. Sheeq iosszs 'Here cansidered ante (findings 41 -42). In an effort to deremihe iicayat2 ~opularions had been efiectzd by the use of 1080, during the Cain Cornittee deliberations, he developed-an index from 

### the man-years of effort and the number of cayates taken by 211 mchods from ?dS rxcrds 

### iar che States o? Yontana, 'riycming

### , Idano, Utah, CJ?orzdo, Taxas, Xew Mexico and Arizona. 3e reascned that i icoyote pcuulations were high, the number of coyotes 

### taka per man-year of effort r~ou?d Se high and that corraspondingly

### , if coyote numbers <,Vera10w, the nurber 

### of 

### coyot2s taken 

### per man-year of 

### sffort wculd also be low. For each star?, he di\iidedthe number of csyotss taken by the an-yezrs of 2ffor: expended 

### foreach year and graphed 

### the rssulcs, in order to 

### csmoare the values prior to the period of 1080 

### use (1

### 440 co 19a8-50) :vi :h rhose prevai1ing during the period ofsuch 

### use (19d8-50 to 1970). The results showed markedly lower index values during the 

### ICE0 period than inthe pre-1080 period for Idaho, Montana, Xyorning and Utah 2nd little, ifany, differences in the other four 

### states between the two periods. 

### He acknowledged that the validity of this index depended 

### on the assumption that the level of effort in predator control by FWS personnel remaiped constant. 706. An index similar 

### tothat of 

### Dr. Wagner's, was developed by Linhart and Robinson in 1972 based on the number of coyotes caught in traplines 

### set by PAS personnel in Wyoming, Colcrado and New Mexico during ;he

.

# -in cnz iac.:?r thr2o pars ,\ere 13, 2, and 21 Fsrcznc, r2saec=iL/e;y of thos? caughc in !Wl, 9rior :he 382 

### of 

### 1080. The nunkrs of coyores caught in Colorado and 

### ?lew~Vexicoin 1950 I,uere substan~ial ly below the numbers caught in 1941. 8y 1960 and 1970, however, coyotz catches equallzd or exceeded the 

### 5941 catch. Validity of this index is, of tours?, dependent ypon 3 consxant level of tr2~iine ei7or-L. 

### Gr. 'iagner pi nEdou~ that 

### these 

### rzsui

### ts appezred co 

### sarall2i ,iai:a inhis i

### naex, i.e.,an apparen rsduction in coyor2 n~mbersin Wyoming, but 1

### iczlo, if any, effect in Colorado and ?kwMexico during 

### me cuo-deczde period of i080 uss. rie no~ed :ha1 

### ehe daca 

### suggest2d tha; iC8O nay have rlduc2d coyox2 pooula~ions 

### maz?rially in 

### tn? normern and c2ntral incermoun~ain 

### states, but had no si gnif

### icanr impact on sta~ewi de coyote populations in ;he 

### nore southerly s~a.t~s. The aDparent reducxion in coyote populations in Idaho, Ldyaming and Colorado did not appear tc resul? ina corresponding decrease in predation (finding 41)


## . 107. 

### in an effort 

### to measure trends incoyote and other pradat~r 

### ?OCL~IZLLICTIS, 

### che FWS in 1972 developed 

### an annual netlaork of "sc~nt-post 1ines" in 18 states. 

### A scent-line consists of 50 

### scent stations spaced 

### at 0.3 mile intervals totaling approximately 15miles in length. A 

### scent station consists of 

### a three-foot circle of 

### bare, smoothed or sifted 

### earth in the center of which is placed a capsule of 

### scent attractive to coyotes and other carnivores. Observers check thescent3tati ons i3r four ~ucc=s~ive ni

### 352?zch fzl? 

### , reczrd r,h$

-, numcer of tracks by :oyot?s and otke-77ariiia i

### r <5r3c!<.~ 0- 2 SZ?C'~S being rocorded as a jingle visic rogardlsss of number) 5nd mcccn :ne soi?for the following night. Results ar? expressed as total visi~s 

### per 1,000 scent-station nights and argoraled for 

### che lines in oach of the 18 states. Sc2n-t-station visits are presumed 

### to bear a constant re1atiocshio 

### to popularion density and the inaices provide only a rneasuru of relative abundant? and not an estirnatc of actual numbers.

. Data from an F7dS pub1ication 

### "Indicos of ?r?daxr Abundance In the Western 3ni

### red Scatss" (1

### 980),wnich r5ports resu; 7s of sc2nt-line surveys, plotted by 

### Dr. Wagner indicat2s that coy~t2 populations appeared 

### to have increased fol

### Iowing 

### me suspznsi3n of 1080 in 1972, declined from the periad 1975 to 1277, inc~~zs2d 

# -1 sl'igh-cly in 1978, and have sinca rernained alxosx constant. ~nis information imp1izs 

### no'significarit change in coyot? populations

## .
, Dr. Wagner speculcced that a possible rzason for the coyotc poculaticn remaining constant 

### or relatively so sine 1972, Idas increased aerial gunning by PAS animal damage control personnel and increas2d harvesc 

### 9

/ 

### - of coyo~es for their pelts since 1975. 

### Mr. Hswthcrqe (fi nding 1C9)
was critical ofscent-1ine survey data, asserting that of60 lines in

9/ This seems a better explanation than the spread of the parvo 

### - virus, 

### a disease apparently fatal to canines, which Dr. Terrill advanced as a reason for an apparent decline inpredation losses during the pericd 1978-80. 

### -

. 

### -an error. 1C2. 

### Mr. Noman 

### i. Johnson, an ASC 'ilildlife 3ialogist employed by :he FHi in A1buquerque, ilen Mexico and a witi;ess for 'dyoming , 

### et a1


## ., considered 1080 rneac-baits a neariy perfect control ~301, in of environmen~alsafety 2nd cost efficiency, for the r2ducsion of ccyoEes local areas. 

### ,de cestifi2d :hai Compound 1080 bait trztions ?rovide the capability sf selectively reducing concen~rations cf csyoces livestock production areas prior to lambing and calving seasans ai minimum costs in terns 

### of manoower and ather opera~i anal expenses. 

### He ccntended that this ";reven~ivecontrol' in 1ivestack procuctian
areas allowed dDC field 2ersonnel to devote nore ti~e problem coyotes, ~hich had eluded 

### the baits or moved infrom adjacsnt
areas.. This testimony was based 

### on extensive e.x:eriencs Yr. Jonnson acquired as a District and State Supervisor of ACC speraiions in 1959-64 and 1568-71 in North and South Dakota, l?4ebraskaand Colorado, during which 1080 impregnatad meai-baits were used far control of coyotes and red foxes. He acknowledged that, lr/hile the need for a bait station in 

### a particular area was based 

### on the presence of coyotes, there was 

### no attempt to determine coyoce numbers or 

### a particular level of coyote population in an area ;he baits were intended 

### to achieve. 

### He also acknowledged that the number of coyotes taken by the baits was 

### not known, 

### because very few poisoned coyotes wet

### e founa.

### - :SS. Xr. Donald 

### ',4.??:~~norne, Stat2 Sb8;ervi;or of :he 12xss,Aninal Sanase

. -. 

### Czntrol ?rzgr;,m for the Fh'S anc 2 .rr; znoss far ',%iycming, 2: 31

## ., 2s:; 7;?< that during his four years (1965 through 

### lS69) of us'ng 

### 1C80 5air stations in Utah and Oklahcma, it,was apparent that che stations provided substantial benefits in reduction of livestock losses, 

## -

. particularly inthe Oklahoma Panhandle. He point~d 

### out that lexts 4as the leading sheep groduc2r inthe U.S. and also the Isding stat2 in Angora goat production. Ye assertd that Tmas shee? and goat production !,vas concentrafgd in the Edwards Plat2au area of lest Czntral Texas, which due to intensive control efforts was 1i:era1 ly

1--m , coyots-free frcn 1945 to 1970. 82 statzd chat sincs th,2 ,r/ L 2an 

### zn :080,strychnine 2nd sodium cyanide, 

### icl,vas no 7ong2r possible io prevenr coy0~2 ingress irito che Plateau ;.,r,.J. 311 ccunr,;es iq L- ha^
srea now incur iivestock 

### IOSZ~S to coyotes

## ., hother important shes? 

## - 1 producing arga 

### ~n Texas is the 

### ~rans-Pecgs Region, which borders the Edwards Plattau 

### on ;he west. 

### Nr. Hawthorne cestiiied 

### chaz shenp 

# -

3 e- production in the Trans-Pocos nad decreaszd by 48 perc2nt since I?:?, many prcducsrs switching to cattle and thoss remaining having great

- difficulty in reducing or preventing predation losses. The 

### 48 percc'n; decrzase in sheep production was based 

### on data compiled by 

### the Texas Crop and Livestock Reporting Service. He regarded predation as a major 

### cause of this decrease and forecast that predation losses52ing inaceouaie fo c~n:ro? ;oyo;e ?reca:ign. 7;; :~s;:'YcI~ ~7:: predasion 1oss2s had grsztlj incrzased since 1972 was also kas2d
on reports by the T?xas Crcp and Livestock Reporting Servicl. 110. In an effort to docnrnenc che effecriveness of 1C80 bait stations i

### n reducing preaaticn

### , :4r. Haw~horne ac~achea 

### so hi5 cestimony 3xc?r?ts from 

### cbe annual r2porrs of cke 745, Prsdatsry Ani~ai Control Operatjons

### , Texas Oisir:c:, f2r the iiscal 'f8zrs 1950, 1952 through 1955, and 

### 1961 thr-ugh 19511. 1: a9Fears :ha: eozt Compound 1080, at least for Fiscal Y2ar 1953, was used in the Panhandle area, sxtogding as izr south as Ward and Crane Counties and as far aest as Culberscn Cxntiy. ,Alchcush :5e rmoris do not contain any s:atistic21 da~a, :hey do cantain abs~rvatie~s o? a great reduction in cayocs si;n and rancher re7orTs gf a reduction or

-, c2siacion ofCoyote predation an cali/es and jheep. : "2 recor: far the Fiscal Year 1955 states thaz senerally bai: stdtions placed in Texas after the middle of January are/of 1iCtle value. blevertheiess

## . the report for :he Fiscal Yszr 1961 states that 1080 stations wer? ~sed effectively to "roll back" heavy coyote infes:af:cns in Webb, Maverick and Duval Counties in the extreme southwestern part of Texas, next 

### to the Mexican 3order. 

### It

### is indicatpd that, although these 

### are not counties with big sheep and goat populations, it is the constanc driftof coyotes from these areas into the,prime she<'and goac country 2 fns 

### nsr-n ana -.as; :hacl-r,usc ze ~~zrciga 2<air:SC.

, . Y,eavy prscaijon :oss2s in :ne 

### shes5 czuncry 

### r ere not ex??r;enc:d, neverthelass, depre~azi 

### ons i

### n chat area wero re?ort?d i

### n every mnxh of the yar. 

### In 

### a subs~quent narrative 

### on the 

### use of Campound iOaO in South Texas, itis reported that coyotes 

### eat the baits as readily in February and Mzrch 

### as they do in N~vember and Secember and that spoilage is r9duczd by cutting the baits into 9ortians 

### not aver 75pounds inweight and placing baits on lags cr 

### sinilar ~leva~sd objects. 111. Predator contrgl reporxi for the Fiscal years 1962 througn i56J j;ate chat Compound 1080 is the only practical se~hod of ccycts conzroi 

### In large arrid areas of che Trans-Peas Re2ian, that consumption of bait 

### has been good (up

### 'to 38 percent in 

### sene areas),that rrzppers' catches of coyotss inimportant counties adjacent 

### to the sheep 2nd goat country have been ireatly reduced, that fwer ccyotes iver? observed in ar2as where 1080 s~ations Nere ?lac?d and that losses were heavy on a ranch adjacsnt ts an ar2a where the landowners did no7 wish coyotes 

### to be removed. it is also relaxed thsz th? 2rsctica 

### of placing land in the "soil bank" created cover for coyoTes azd that traps, snares and "coyote gettsrs" were still being used and were "hard 

### to beat" wheq correctly applied. Compound 1G80 stations were considered to be useful to reduce coyotes to 

### a lower level in the i big cow country.1. ?rocjrarn for the 2yonlng 

### 2e$ar~zen,~f Xgric~izure 2nd a ?q::nass fcr Xyoming, 2c dl., cestifiea as to he us? of Cc~scund :SaO bai: 1

### o/ 

## - stations in %yarning during the period 1975-1977. Dspar~rnent employees, who were qualified 

### as certified applicafors, began ?lacing baits in assigned areas of the State on or about October 15, 1975. 

### Rancher certification of predati

### unn 1osszs 

### as lwei1 

### as lanaaw~er cansent 

### toplacment of Sai" were rgquird. A total of 

### 1051 ~aits der? placed on 399 ranches in

### che 1.575-76 kiting grogram. 3ecauss of heavy Pzeding oy predators, baits were r3piaced cn approx'natziy 43 ~ercent of the ranches. Baits Ner? again ?iacod 

### begjnning cn dovember 3, 1375, a total of 1,005 baits being placzd cn 373 ranches. 11,'. 

### Mr. Crosby consider24 ihe program a suc'zess, ci~ing ~h2 'F,*iS pub1ication "Indices of Predacor ,Abundance i n the 'tiestern ijnited St;t,ls," ivnicn

1O/ Although an injunction issued by the Fzaeral Clisirict Court upon the gzund EPA had 

### not complied with the National nvironmental Policy Act prior 

### to issuance of 

### the order susgending and cancelling registrations ofCam~ound1080 for ?redator control in 1972, was overturned (Wyoming 

### v. Hathaway, 525 F.2d 66, 10th Cir. 1975), Wyoming took the position that itwas entitled ta us2 1C30 for predator control under an intrastate registration in accordance ~ith 

### the provisions of Section 24 

### of FIFRA and 40 CFR 152. Use of 1080 for predator control in Nycrning was hal2d in 1977 

### as part of a settlenent of an enforcement procgeding instituted by EPA.30

1 -'l 

# - snowed ;he ',4ysmivg index i,r 

### coy?;es ir IL. L jn 1275 and 4: -1

. >

1 

## -- and 11.2, res;ec::vel y, j

### n the ]ears ; 375 and I 91 1

## . ;?2 3:33 ZI 124 dara callecred by 'he 'iycrning Crop znd Liveszock 2epor'i ng Ssrvice
on lamb losses co coyois for the years 1070 :a 1980 inclusilie, which snowed, inzer alia, 

### IOS~~S of 84,5GO 3r 

### 8.5percenr of lambs born in 1974, 72,000 or 7.8 9ercent of lambs born 

### :n 1975, 65,000 or 7.7 percent in 1976, 

### 51,000or6.1percent in ; 077, 43,500 or 6.1 lpercent of lambs barn in 1979. While he acknowiedged chat there wer? fluctuations in losses of 1ambs 

### to coyotes in other years hich CJU!~ not be atzribuzed 

### to the 1080 baitins prcgrm and which he could not explain, 

### Nr. CrosSy maintained that :he reduciion in losi~s dur: ng the period 1976 ~hrau~h 1973 was due at 122s: in part co use of bait 5:at:sns. 114. ;!r, Harry Laati, a Harhematician, Presidenx and Chief Scient; ST of Loats Associat~s,Inc., a firn specialjiing inoarhematicai dna1ys:s and modeling related to population dynamics, host-area napping, risklbenefit assessment igr ?esticides, pes~icide driit and other natural resource relat2d phenomena, and a witness for USGA, jubmic~ed the results of analytic evaluations of animal population dynamic; (modeling) based upon actual bait consumption of 1080 large-baits at 640 sites for which data was available inWyoming during the 1976-77 period. The analyses were performed under 

### a contract with the Animal Plant Health Inspection Service (APHIS) of the USDA. Expected sheep and lamb loss reduction inYyorning 

### was computed by aggregating individual bait sites ineach count;,y into Crop Reporting Districts

### 8 

### I

, . (C2Cs: and J:/ zl/alliaz?cgor :rcj@,--- -L ;?? 1:~:: 

### zzr;u,~c~ion zver a czn- ]ear ;erj;c 3 is\ielsi-annig :% i, ;licala 2i.o 

## per r-njz s?

-. fieid gar?er?d sai

### z consdxpclon daca for 2acJ 32. I ne r2sul:s indicatsd 

### tndc popuiaxian reduction of coyotx 

### ircm 1080 baic placements in high 

### sheep vu1nerabi:ity areas could result in sheep loss r2duction estimated to be approxirnaieiy 

### 7,000sheap and lamb per year. 2e defined high 

### vuinerabi1icy 

### areas as ar2.s tihers har

### t:
were ?laced 

### on ajsuned 

### reda at ion 1~~~2s :3 shee~ ~cd a hi~h coycte densicy. The nodel is hypothecfcsi 

### , -here '~eins qo rs.' method 

### aizeasuring population (coyote 2nd non-target) densities for the who1

### e area, 

### rsource (apparent1 y 

### ?red avai1abi1i

### ty was assumed ;o be 

### cgnstanc and baiz consumotjcn Sy non-car2ec.s was 2stimated bas2c 

### on zssessiiients ofbaic 3ctracr'vcness cc sucn 

### saecies, bait visi

### ts

### , cansumption and popu?ari

### on densicies


### . 

### ,Yr.Loa

### ts isstifiea thas the model co~il a be used to ~2s~ cbe actual use of 1080 over a cen-year period in Wyoming, ?rovided data on gait consumption rslative 

### to distributed si;?s, population 

### densizy, ztc
were available. He acknowi2dged that the output of the rncael depended 

### on the validity of inputs and that inputs such 

### as efisct 

### of 1080 

### on population dynamics of 

### tar~et and non-target species, animal specific data inputs, trapper ffeid 

### sxperienc~, locations and densities 

### of target and non-target species, attractiveness of bait sites and their probable effects on species, animal presence and abundance, were supplied by animal managenent experts., i.s., jr. Lyle :r-~s~y and ioiiii fl~ua of ,;;niS. nt also acknowledged 

### that dispersal 

### or migration of coyotes 

### was not considered.1 r 

### . George 3. 30s'. 

### , a recired am1 oyat? 31 :he 

### '\is ri:n 23 

### Lie2r-s exper.ler,ce in

### rhe (Anizal Ozrna.32 isncroi Pragrarn, i;?s;den; 3f ne Yational Animal gamage Conirol Association, Inc. (YAGC) and a witness for the Association, cestiiied that -he us2 of Ccmccund 

### 1080 in large-bait sta-cions was effective in reducing coyate numbers co
a 1eve1 where the agiicultilre-business carrnunities could sur-ii ve

### . His data on efincrivenesj apoeared TO be 

### bascl srjnariiy on :he reduction in the number of bait jtaiicns places in E4S Region 2


### - (Arizona, Cclorada , Xew !exi coyOkiahcna

### , Iexas, Otah and ',dycming

### j 

### from a hi~h of approximately 3,10Qbaits jn i962-63 

### to a law 

### of approxima~eiy 4,600 in 1963. He indicated 

### tnar :he deccreasei number of baits placed was rela~ed 

### to the lower nunber of requesIi fr3m AOC 

### iraF;?rs or district field 

### assis~anss (3FAs) in the cis;riczi, who were in tlpe XST position 

### ;o assess the need for such sti~jons. 

### 1 115. r, Jchn R. Zeck, Preslcent of 3ioiogical Envjranme~.ralicnsu1:ant Serviiss, Inc., a former animai damage c3n;rol 

### zcjenc for the F,iS with 

### cver 32 years experiancs in predator control and a vfitresi i-r Wyoming, 2~ 21

## ., reiatad an incideni concerning i sudden inc?ease n coyote predation 

### on 1zmbs and ca? 

### ves in rhe early 1950'i in .'Icr-hwestern North Dakota near the confluence of the 8ig Mi~souri and Yellowstone Rivers. He testified that while it

### aid not appear that coyote numbers had increased, predation certainly 

### hzd and that removal of many coyotes by traps, aerial hunting and coyote getters failed to abate the losses. Losses were attributed 

### to coyote movements concentrating coyotes in the area and a baiting program 

### was instituted

### . -, -

### -_- 

### cI~s? s=gezr.er 2s ryuia

### :iazs al1:wed zr;d 2ac,2nd~ 2rear :r 

### ;r,e , ; ,, 

### ,s :ili

### ssouri 7i.rer was aljo 

### 'Lre~ceu. ,Accorbin~ fcl ?lr.3ec:(, t52 ZZOU~L (;f 1080 

### treatzd bait cgnsuned inhis assigned ar22 S~ring chac ~ericd 42s greaTer 

### than anywhere 2152 in the Unized States. He testified that during the next 

### fouryears ?redation in that araa was 

### ata very low rats and that 1080 

### was not uszd there che next season, there being
no need 

### for it. He vias 07 the apinion that with quaiifisa applica~ors Compound 

### 1080 was a major gosizive factor in canid predaccr nanagesec:.

11- I 11.

### Nr. 'clilliam 

### K. PSeiier, a aiologist, Supervisor of (Animal 3anage 

### Control for the FWS 

### in Yor-ch Cakota, having abouc 25 years 2xqeri~nce in predazor and coyote control , and 3 witness far Seiencer-s 

### of ':/i 131if2, 11 

### / 

## - etal., testified that they? lIvas 1ixtle dcuoc :ha: km~cuna 

### 1280 bait j~ations had rzduced 

### sne coyote ;cpuiation. Ye ?s~irnat?d;he reducT'on ac aaou? cne-third of the ~o~ulation. Strychnine ?TO?-kits
were also used prior 

### to 1972. 

### IYr. Pfeifer testified 

### tnaz silee:, 

### losses to coyotes increased after 1972 going from 0.25 percsnc in 1972, to 0.42 percent in 1974 and 1975, 

### 0.48percent in 1977, and then declining 

### to0.13 percent in 1979 and increasing to.0.33 percent and 0.28 percent in 1580 and 1981

### , respctively


## . He was of the opinion that these figures, which include only ADC confirned losses, supported 

### the effectiveness of 1080 inreducing predation. 

### He attributed che decline inpredation after 1977 to 

### a harsh winter and an increased harvest of coyotes for their pelts.

. - I 1

### I/ Mr. Pfeifer was called 

### as a 

### witness by Defenders because 

### he had cGducted or supervised 

### a survey of North 

### Dakota ranchers using guard dogs for predator control.New flexic~, and 2 witness for ',4ycrning, 2ta1


## ., xstified tha"s 1CEO largeAaii :tations were 

### an 2ffectivemethod for reducing coyote predation on sheep, goacs and calves. He based chis conclusion 

### on the fact that placiqg staiians resultsd in fewer signs of coyores

### ,

, 

## - such as tracks and droppings, :ewer damage 

### c3muIainis and a rzdticed catch of coyctes by trappers. Mr. Anderson ii

### rst beczme inv~lved in 

### the placznent of 1380 bait sbtions in 1362 in an area satith 3f che Edwards ?lateau inTexas and which 

### he referred 

### to 3s the "coyotz factory of the Uniztd Staces. " He also ?lacad and supervised zh2 piacenenc of baic stacions in Colorado and U"ch during che jeriod 

### 1964-67. He tzstified chat after 

### the ban on the us2 sf 

### 1289, icdicators ofccycce ;3opuiati 

### ons increaszd, citing 

### an ins-tance i i.1 Eray County, Texzs where 40 he1 i coctzr-hcurs o-f hunting resu1ted ;

### n


### a huge 

### take oiapproximaceiy 290 coyotes. He asszibTeatha-, while 1080 was inuse ?pproximately 25 to iO percent of that numDer c7 coyoces would be expectod 

### to 

### be taken by that dmcunt sf aer'al huntiog

## . 119. 

### Dr. Samuel Beasom (finding 95) conducted 

### a study in 1975 and 7376


### on the efiscts of prsdator control on Angora goat mortality in northern Zavala County, Texas inthe South Texas Plains. Surviva- , bility and productivity of Angora goats were compared between a 225-hectare treated and 

### a 207-hecQre untreatsd (no predator control) pasture. 

### The study area is known 

### to have a heavy infestation of

. . coyotes. 

### The 

### two pastures were separated by seven kilometers.,Vai-mai im srzdzfsrs .rers ~emoved 

### frxa !,55C heczar? -?re2 incl!ic: ng

-, ine treated :asiure 2nd 2 1.s i:n. juifer 

### zone an rhrer i,ldss. Six:;/- nine coyotes, 11 bobcats and 32 smaller namaiian predzi3rs :Vera ki1led on ihe tr2atier;c araa in 1975. Tile 

### cake in 1976 was 

### 63 coyotes, seven bobcats and 32 smaller predaiors. Predaizor ac;; vi

### ty


### on the treated area, dersrmined by scat counts, was 80 percen: 1esi chan chat 

### on ihe untreated area. Pradation 10sies on the untre::ad 9asTur-e were 33 percenr 

### ci?he kid crco, uhile nnkncwn l~sses (disappeared without a trace) totaled 52 perc3nr 

### ci the kid croo. Ccnparahle figures 

### on cne treated pasare were 16 percent 2nd d3 rercent respecij-iely . :dost of th2 unknown losses were actribur?< to 7redators because of the prosence of coyote scsti ccntainlng mohai

### r concurrent ',~i :h an animal

### 's disappearance, because survival
raws 

### were hisher gn tne creatod area and becaus2 disels? and abnomai i ties zrnoncj rhe ?id crop Nere 

### rzre. ?r.-dation 

### sf scu:: goats yas 24 percent of ihe iiock on ihe untreated ?asiure and zero
on 

### the ireated area. The study concluded that intensiie ?recator control could iubstantially increase the sur-iilial rat. of kids and goats, bu? vas insufficient 

### ra curta:! large losses 

### to pr2iafion when conducted on 

### a small scale 

### or 

### a: d level no grsater than thai in 

### the study. 120. Basic to the oqposition 

### to the use of Compound lC8O in large-bai

### t stations is the contention that-heavy and sustained exploitaizion of coyote populatfons merely results in increased reproduction, iowerthe sane and char zrianprs 

### xs sappress ccyo~ popularians 

### over ,qide
areas 

### are cauntzr?roduc~ive and aoomed ~3 Tailure. Opponents 

### of 1080 

### a7so contmd that there is no demonstrat2d relaiionship beween coyote ?apulations and livestock predation. The coyot~ tak~n;ernan-years-of-2fi3rt index develcped by 3r. 'dagner and his csnclusisn chdt 332 of 

### 7C80 apoo3rad co suoprss coyote ~oouiar'cnsin s?e early period ofitsuse inine Scares of Icaho, Yontana, iyaning and Ucah has previously been aentioned (finding ICS). Dr. Wagnsr no~2c that the sopulation reducrion did not 3pcear 

### to be lasting and thac there was no corresponding reduction in ~rzdacion. 

### it snouid :e noted 

### , however, chat 

### Dr. 'blagner acknowledged :"2~ appli casion 9T intensive ?reciacar control techniques in zrz?s I czuld degress csyoce popuiations and reducs ?redation 1osses

## . Dr. 

### Grand. (findi

### n~ 31) impliedly recognized this fact when he excused the heavy precarion 

### losses on the Cook Ranch in Montana 

### as a "no cantrol" study. 121. As evidence that coyotes can be removed from a l3rge area, the Edwards Plzteau area ofTexas, which was litsraily coyote fr2e during the period 1930-70, 

### is frequently cited. Coyotes were reportedly removed from the area by the use of stzel traqs, strychnine, and hunting, aided by fences constructed for livestock control. Itis 

### not clear, however, whether this 

### was an area of historically large coyote populations 

### or whether the principal predator removed was not the red wolf, an animal less adaptable and more easily extirpated than the coyote.

### - 122, sxay ;uhicn ?;<amiced 

### rne ZrTzc: 2f 3~;lgi;~;j:n an :2:/9:2 &
-. ;opui aticns ,vas csnduczs* 9;~ Sr


## . ?;cerx ?

. ja(jjjan, L??:s, 3;; l,se 

### ?~pr2sznca:iva for t5e Fi

### sneri2s and hi; 21if2 Frogran 37 Tge >la-iofiai Iriiid1ife cecierati'on and a witness 

### for -,he ;\I11F, 5s par-, 07 ni; doctoral di

### ssertation. The study

### , conductzd during the pericd 1974-78, examined separate coyote popuiations in the Curlsw Valley of Utah and Idaho, which -,vas 

### subject t3 

### noderate to high expioication, and on ",he Idaho i?lar,ional Engineeri

### ns Labora~ory (I?IEL)

### , lt~hich was
-, considered to be unex?loited 

### or at 123s-tmoderafely so. ine stzdy
areas are approximataiy 

### iGC 

### km apart and ~nvironneneally similar. Avai1abi1ity and uti1ization ofpr2y 

### were a? 

### so simi1ar. Nei?her spring nor fall,density esiimaces oF coyoIes '~er? significantly different 

### betwen araas inany siven year 

### or 

### cvsrall. Huncing accounted for rcughly 39 percent of all adult coyote iosszs and 

### 54 percent G? juvenile deazhs jn the Curlew Ya112y. About 25 

### percznc of adui1 deaths and 12 ?er-c?nx of juvenil? deaths were due co hunting in the INEL. Or. Cavison concIud2d thac his study showed chat substantial exploitation would not be effec-,ive inreduciny coyote densities over wide arEas, becaus2 ?x~loita~ion losses wcuid ke quickly 

### offset during fall and winter by reduced loss2s to other


### causes and by reduced migration and 

### are further offset 

### the following spring by increased recruitment (birth and 

### immigraticn)


## . He concluded 

### that increased recruitment would prevent any lasting reduction in coyote density. Despite apparent differences inthe levels of ~~u,;,zIT 

### expi01 iai10fl,mere were t10 stacihilcaiIY signlr

### icane --significant differences in hunting caused deaxhs of juvenile coyotes bek~een the t-/o 

### areas. He acknowledged -,hatconventiona1 1,lrisdom among trappers and biologists was that juvenile coyotes had lower survival rates than adui

### ts and (were

### mar: 'vulnerab;2 ~2 sx?lo't3cion He 

### also acknowl2dged that no effart 

### was made c3 2valuaz the ievei of coyot? concrsl 

### on arlss adjacent :o rhe sxdy areas srd :?a: dzfini ng any cgyote or di7dli f2populaci

### on Has szmewnat arbivary.

9. i23. Testimony that coyotes wers primarily scavengers, re!zctanx 

### ra risk injury by attacks 

### on animals of any size, ,das given by iioce Ryaen, an author and a ;vitness for Fri 2cds of Anina: 5, Ific. $,rno had spent over rwc years clos21y observing packs of coyot2s inWonczna and 'dyming

## . It appe?rs, ho~ever, thac 

### Ms. Ryden's observations
were made primarily in the winter months in areas of heavy snow
cover and that animals the coyotes did not attack \were aduit elk, deer, bighorn sheep and ant~lope, lwnich would nomaily b? of suffici~nt size 

### todefend themselves 3gai

### nsc c~yot2s.2er observafions *Mergmade 

### on packs of coyotes in Yellowstone National Park and National ElkRefuge and thus the coyotes were protect2d fram human exploitation. She acknowled~edthat during the spring and summer, coyotes were primarily predators 

### on small animals, such as rabbits and rodents, and that they were opportunistic feeders and did killthe socjzl or;.zni zati33, azc!~ hjzr2rchy 2nd <?~ri<~yj 4 igcer.;j!,es

. *


### s~abiiize 3t a iower level, wi-ch the likely cansequence of 

### a lcwer 

### rate of 1ivestock predation. 124, Dr. 

### Franz 

### Camenzind, 

### a 3io'iogist and 3 i~i~ness for Friends 

### of Animals , T'nc. 

### , Inno has conductxi 

### stens r2~2zrci; 3n CZ:IOC~~ ?opuiaticns ssentially 

### frwofman-caused ~ortali~y, supporr~d tne thecry that 

### a s~able, unex?ioiz2d coyote ?o~u?ac;on would 1ikely lead 

### to 1

### ower rates of 1ivestack predarion. 

### ;3eooszrvea ccyotes over an eight-year period 

### on the National Elk ?ef~ge near Jackson dole, Wyoming. He 2scified :hat 3 s-,abl2 coycle2 oopu;at;on consistxl of social unizs or packs of from four to six adul~s bav-,ng clearly xfi ned 

### nierarcnies orpeck orders and 

### we! 1 deiined, territori

### es

## . 3e 2xplainec! that wi:h ixoder3ce 

### to he3~y conzrol , tne social structure becomes disrup~zd or destroyed, 

### the population is in

### a constant stat2 OFflux, terriccries are not ouclined or aefsnded and that the rgsult may be 

### nore prey killed per coyote tnan would oe the case in

### a stable population. Contrary co 5cn2 theoriss, 

### Dr. Camenzind did not find 

### that 

### a decrease in coyote populations resulted in an increase in litter size. He acknow7edcjed that the us5 of poisons could 

### reduce the number of coyotes. 125. 

### Mr. Eugene Allen, Administrator of the Wildlife Division of the btontana Department of Fish, Wildlife and Parks and 

### a witness For the State, testified as 

### to the results of 

### a study of coyote ecology

### I1with neck co1:ars. Coyotz density in the approximatsiy 1C0 square-mile study are3

### was deternined co average approxi:na~s:yone 

### per square-qile during the summer. The study of cayofe r,overnegTs cancluded ?hat coyoizs cc~uldgenerally be clcssified in13 one of four socia1 benavior 110d2s : den breeders, den su2er nuxer?ries, nonads and d' saers~rs 

### . ;en bresctrs lrrere ;~cu 1

### t pzten-5 3f a 

### ::7~27. Den supernumeraries aere aaul

### ts and prooably pips frm <he ?r?vious year. ?lomads ,>/ere adult coyot2s, which lzf'~ the den area 2nd ?stab1ished 1arg: 

### :rzvei are2s. 3isqer;al csyo~zs were young, supernumerary or injurzd den breaers wnicn 2er~zrentiy 1ef~ the study area. Den coyotes ccnstit~ted ~poroxinatelj LO 3ercant of tne

nnnvl I ,,,,l ati

### cn and naz nome ranses 07 three or four square ni1es. 3:hsr coyotes ranged over areas from 30 

### to 50 squar? ni12s. Dispers!ns coyotes were killed by hunters a5 distances From 2isht 

### to 95 qiles from den sites. A conclusion of the study was that an effective coyotg control progran must have the capability cf addr2ssing sitespecificproblems caused by den coyotes with 

### a very small home range 

### or site-specific problems caus2d by a nomad coyote or dispersing juvenile coyotes. Pr~dation control was practiced 

### on the study area and itis questionable whether this study can be said to contradict the Ryden and Camenzind theories r2ferred 

### to in the preceding findings. 126. There is csnflictfng evidence in the record as to whether coyotes become bait-shy. Ur. Crosby (finding 712) asserted that the existence of such shyness was pure speculation. He acknowledged,. e coyotss for one r?aszn or anoc5er and thar ;r 

### sne ~~s~hoa of coyo:? concrol was used constantly, bait-shyness could develop insome ci rcumstancas. 

### Mr. Richard Randal1, 

### a fcner OFA for the F,iS, Ncrth Czntral Field 

### Representative for Oefenders cS Wildiifa and


### a wi~ness f~r Defenders, -+/asof opinion thzt ccyotss did learn 

### to avoid or develop 3n aversion fo bairs. Vr. ?obert ?ur~eo, an AGC agent f~r the Sobth Dakota QeparaentofGame, fish and Parks :vi-lh 37 years 3f~xperienct in trapping and 

### a witness fcr the Stare, testifia 

### thar he would have to be convinced of any 

### such shyness, because after consumjng the bait 

### no learning sxperiefice by a coyote was possibl?. it does appear, 

### hcwever

### , tha: 'he effectiveness of baits declined over tine, wnich has been analogized 

### toresistanca co pesticides developed 5y c5rxain insxts. Yorzover, 2r. 

### Xajzr L. 3oddjc~er (Tinding 

### :GO) tzszifjed -,ha:: con~inucus iise of a particular baiting system resu? 

### ts indevelopment 

### 07 cgyote popularionz with 

### a high proportion of coyozes nc~ attractxi to mat baiting systsrn and cnac by 1964 itNas widely accepted snaL 

### 1C80 large-Saits were unacceptable 

### to sotTe cayot2s.


### Issue 3 127. Testimony 

### as to the eii?ctiveness of dmning, shooting, trapping and 

### snaring in reducing predation was remarkably consistent whether from proponents 

### or cpponents of the 

### use af 7080. All seemed to 

# - i +. ,-A< -0- :cr:z SL3;t 

### ncnc :" ",.S.E 

### (*:e??2j5fsc:' :;73?.+ : 

## . , , , ,,, , 

## .regarded as a jclution ts the ?ro~lem sigredarion. For 

### ?xampie, 

### Hr. Randal 1 (finding 126) described 

### che process of denning, that is, locating the den 

### where coyote pups are bein! reared, 2s requiring tracking of zdult coyotes. Cejending 

### zn corrain, thjs crsck'ng vay be very dif='cul 

### t and ~ime csnsilrning and, in my event, roqu;res experience and skill. 4 table in evidence, reflect; :taf in 

### 1976 6.2 9etcenx 1Fcoyotas xken cy ,4DC rrersonnel of tne ?AS 

### ere :aksn by denning. 

### Or. IdaCe testified that removal of denning pairs 

### of coyotes or their young may, and frequently does, ;Top 1ives;sc!<

-. ?rodation in 1scalizdareas. This isstimony was icnr:ned by Yessrs. F. Robert jendersan and Edwdrd 

### K. 3oggess, /r'ildlife3i~lcgi~ti, Coooerati11e Extension Service, Wi1dlife 9arnage Control 

### , Kansas. State 121 dniversicy- and witnesses for Menders. 128. Aerial hunting or gunning isprobably the most effective way of 131 

## - shooting coyot2s. Use of this method has significantly increaszd since the 1972 order sus7ending the use 

### oi toxicants for predacor control


## . A tab1

### e ref;ects th~t in 1975, 40.2 percent (28.6 Fercenc by helicopter and 11.6 percent by fixed-wing aircraft) of coyotes taken by ADC personnel 

### were shot from the air. Terrzin and heavy

12/ Mr. Boggess has changed his ernpioynent and is presently employed by thF~i nnesota Department of Natural Resources, St. Paul

## . i3/ 311~ccing or ~;un;ing wi1a;ir.e iiam he air- 15pronioite~ 2xcepc 

### - unders'tate authorization 

### or per mi^ (16 USC 342j). Kansas and Arizona have not authorized aerial hunting of coyotes.. 

### -- hiding placzs and :.+us rlncsr aeriai. 

### iunx: 19 ;Y?TT?C:~I~~. ,~~Z::ST conditions aay 

### also prevent or inni~i t aerial fiuncizg of coyozes. iiunting coyotes from fi xed-wing aircrait can be hazaracus



### . >It-

### . 2andall (finding 1261, who while an FWS e~ployee, shot hundreds of coyocss from 

### the air, having been involved in b,ro plane trashes, 3nd Mr. ;?awthorne (findirig 109) a? 1uding 

### to 

### a fa~al crzsh 05 dn AOC 71ane inNew Mexico. Us2 of he?icopt?rs is probably thc ,xost 2ffectjve and least hazardous way cf hunting coyctas frcm :he air. Gperazins a he1icopt~r is, however, very expensive, as evidence inthe rscord ij
t3 the effect that tbe hourly 

### cost of such opera5'on 

### has riszn frcn 590.00 zo 

### as high as 5375.00 during tne last 

### eianc to ren yezrs* Aerial hunting is, of c~urse, selective 

### tz cayozss. Exx2nsi1ief;yi rag wnereby every coyot2 observed is rhoc, is, however, not selective c3 coyotes depredating on livestock. 

### Mr, Randall tzrned 

### s: "war 

### on 'be species" and asssrted chat itdidn't necssariiy solve a particular rancher's predation problems. 129. Coyotes ar?, 

### of cours?, hunt~d from the ground. 

### ADC personnel shct 6.3 pwcent 

### of coyotzs taken in 1975 from the grcund. A nethod oS luring coyotes within gun-shot range is by 

### use of a call, which 

### mimics an animal indistress, thus bringing 

### a coyote in search of a meal. Coyotes are also hunted by sporxsmen and those 

### incorestxi in taking coyotes for their pel

### ts. Herders and ranchers frequent1 y carry rifles and shoot at

### coyotes they 

### see. While this scares coyotes away,

- - itis unLItely 

### enat many--coyotes are ia;cen in Lnis 

### manner.13G. Tr2pping by tnle IS? of s:20; le3-nolli Irzcis is a xrz61;:~na7 and 

## - 7 47,- err2czivz rechod ofpr3ca;or conzrol. In IY/O, 37 Gercenx 

### of


## - coyox~s taken by AGC personnel were taken by trzps. I,r-a;s frequently become inoperable in 1~1-1 and freezing +leaxher, 

### ar? frequently .disturbed by livestock and non-target animals, requir? considerable ski71 as 

### to placernent and require constant chec!<i ng t3
assure operabi1 .izy

### . Coyo~s beccne cra~-wi s?. ,A1~kouch the selec~ivity of traps 

### can ze impraved by increas'ng :he ,;aR xfisicn
so that,the trap will not be sgrung by smaller non-targ2t 5peci~5, traps are nan-sglective. If the tr~ps are not cneckzd ircctiently,
an animal nay be caugfit in the ',rap for days or a week 

### or more, x~nich 

### is not humane. 131. Snares are sinply 

### a wire locp placzd alang a trail or rioro freouent'y
a hole in 

### a fenc2 in such a manner as to encirclz the neck of an animal attmpting 

### to pass. The loop tightms and the aniiilal usually strangles to death. 

### In 1976, 3.8 percent of coyotes taken by ADC personnel wer? taken by snaros. Coyotes may jump fences and the
snares may be rendered incpersble by weeds or brush growing or being blown into the opening where the snare is set. Snares may a:so be rendered inoperable by 

### 1ivestock or con-target species


## . 132. The N-34 is a spring loaded cylindrical device, which when act'>iated by 

### a coyote or other animal tugging on an attached scent or lure, expels a charge of sodium cyanide into the animal's mouth, killing it almost instantly. The 1'4-44 is quite selective 

### to coyotes and foxes.In 1975, 6.3 prc2n: 2r' C:;ICXS :-s.c@n 3y .j2C 29r50373; :,3r'? xkzp,

. 

## . by the 3-Ll. 5cne sci1 concic;cns 

### ar. corros~ve causing cecnzn: ca I problems ltiith 

### the ?I-44 and heating and 

### cooling of <he units br2:ks the 

### seals and allows muistura c3 psmtrate the sodium cyan-ide cartridge, 

### thus rendering the )I-43 inoperabl2. They are a1so rende-red inoperable by livestock and 

### ?eo~le and 

### are ineffective in

### warm weather bsca~se 

### coyotss are not attracted c3 

### cne scents. 3ecause of 

### thes? ?r3012ns 2nd 

### the restrictions placed on iss use when it was regis~ered in 1975, nany ranchers are dissacisf'td with 

### che H-44. A 1979 r9port by che Texas Crop and ii\/escock Reporting' Serl~ics revealed that only 14 pe~cent of 

### I,195 rznchers 

### resgonding 

### to tbe survey w2ro using ,Y-24'5. 133. Averrive conditioning using iizhiurn cn:srid? 

### (IICL)as rhe aversive

-, agent 

### has been laboratory 2stdby zne F1,-lS. ;ne theory is mata 

### coyore or otner ~redacor wi:l become ill from ingesting 

### Jeaz such
as nutcon 

### or baic 

### laced with LiCL, will associate the i1

### lness wi~h the particular prey and thus become averted and refrain from attacking sheep 

### thereafter. Mr. Guy 

### Connoily,Nildlife 

### Iiesearcn 

### 3iologisi in the Predator ?ianagement 2es2arch Section of the 

### Denver ',+Jiidlife Research Center, 

### FWS stationed 

### atTwin Falls, Idaho and a witness for the FWS, described the results of these tescs. 

### One gram, 

### wo grams and 

### four grams 

### of LiCL 

### per 500 grams of bait were tested. 

### Mr. 

### Connolly 

# ' testified that 

### coyotes didn't like 

### the salty tasZe of 

### LiCL and that the 

### tests here designed 

### to produce 

### the most 

### violent illness 

### ~ithoutLiCL save tne longes; dversicn :ine, an av2r3ge o? L.3 days be?ore the coyo

### ies again began eazing 5aits

## . - 134. In a second group of tests, eighz coyotes of approximat2ly the
same age 

### wer. divided into two grcrups. One group (experimental) *as fed jackr~bbi 

### t Dair containins LjCL far three consecutive cays, 

### wni1e ' the orher (control)

### was f2d jackrzbbit bait wichou~ 

### LiCL. 3n the fgurth day sach grgup was given ;he choic? 

### o= 3 livechicksn 

### or 2 1ivejackrabbit, che theory beinq chat ;he experinentai sroba ,vcula 

### eatmore chicksn and 125s jackrabbi;. 

### Yr. Connolly t2stified that there was no aiff2r2nc2 

### as each grcup kiiled :he same number sf jackrabbi cs and chic!<ens. 

### He resarded 

### t>,etat: as 3 fai1ure, asserzing ;ha< they have since l2arned that there is 

### no dosage 

### a? LiCL suiTicient 

### to effect coyote behavior that cannot be dirxrek 14/ 

### - by them. These were all laboratory or pen tests, na field tests having been conducted. 135. Dr. Carl Gustavson, a Research Psychologist, Associate Professor of Psychoiogy atNorth Dakota Scate University and 

### a witness for Defenders, cited he results of a szudy he ~artic'patedin on the 3,000-acre Honn Ranch in Washington State as demonstrating that aversive conditioning using LiCL laced baits could be effective in reducing predation. The study, begun in January 1975, involved the placing of 12 bait stations 

### using two types of baits: one of dog food laced with LiCL and wrapped in

### a sheep hide, and the second,

la/


### .This conclusion 

### was based on research conducted by Dr. St~lart ~llinsjfindlng i38, infraj.8. carcasses of shee?, ,,vn;cn hzc 'Ied of natural iauias, *ere in;ected

bait and the solution injxtzd into 82.4 grams 

### of 

### LiCL per liter 

### of dattr. Dr. Gustavson indicat2d that he would 

### recamend using 

### a slightly lower dose of 

### LiCi at pressnt. The study conducted through Xay 15, 1975, suggested a reduction in

-7 predation lossas 

### of sheep 07 -from 43 cerc5nt Co 50 percen1. .r,e report 

### on chis s:ody indicasss tha~ :he range oforedaaiion r9duction
was 

### from 30 

### percent tc 60 percent. This was based an a ccnparlion of the rancher's pr2dation 105~2s for 

### zne preceding three years. The wide variation in ~ossi bie predaijon reductjon was z::riLu;ed :s uncertainty as 

### ia (whe~her parxicglar losses 

### 'were due XI coyotes. 

### Dr. Gusiavson acknowledged that because of the inabiii :y c3 incorpcra~e acequaie 

### cantrois, ihe jtud~ djd 

### not canclusively os~ablish :he efficacy of aversive canditisning iodeierring predation. Yoreaver, 

### a dispute arose between the reszarchers and the rancner regarding the determination of coyote kills and rh? result5 of this study were left in doubt. 136. Dr. Gustavson also cited 

### a study inwhich 

### he par~icipated 

### conducied in Saskatchewan, Canada. This study, conduccad over the three-year period 1976-73, involved the distribution 

### to ranchers 

### of ground 

### sheep meat wrapped and tied in sheep hide laced wich 

### LiCL at the rate of 6 and 4 grams per 100 grams of bait. Ten flocks having 

### a total mean size 

### of 10,508 cornpleted 

### the three-yezr tesr and fulii l

### Ied requirements1977 and :.52 ;erz2nt in 1972. Analysis cS varianco 

### indicaf~d caaz the reducticn in losses to predaars was sign'ficent. 3ecsuse flock sizes for each ranch over he four-year periad ar2 given in terns a? means, while the rsported perentages lost to coyotes 

### werz averaged, itis not possible to detsrmine acziial 1oss2s 

### frsm bass siicmicr2d. The jtudy concluded, however, char the evaluation did not zllow for the specificacion 

### a? prggrzrn ~1arAa1~s responsible for r-he rxuczxn in losses and that factars such as a possible 

### incrnas2 in nccsers gf coyotss 

### taken for their pelts, possible bias or 2rror incet?matizn
-+=,A da LUU* 

### oicoyocs kills, and activities 3n the ranches could not 

### Be sva111 It*Has also nor-xi :hat, facrors such as r3?eilancy r2';ker 5hzn
aversive condi

### ticning may have been involved. 137, Dr. Gustavson 

### wai critical 

### of the study referred 

### to Sy yy. Ccnnojly (finding 135). His criticism, however, was based 

### on a 1i teral reading of the protocol oithe study.as "zhe test situation 5eing repeated daily unxil each coyote had killed and f?d on thrze or more jackrabbits and one or more chickens." 3r. Gustavscn contznded that the number of animals 

### to be killed was established by the ~rotocol, that there was 

### no dependent variable and that itwas inpossible for the 

### two numbers 

### to differ significantly. Because there 

### is no indica~ion the number of chickens available to the tredtiient group was 1imited, this criticism 

### is 

### not valid. 

## -- . -El1ins

### ,a 2€s?arch?sychcicgist, ?rofes;or of ?s;/choI osy aCalifornia State Col:ege, San Sernzrdino and 

### a witnsss for Defsnderr. 

### In 1976, 

### the firsxyear of the study, 

### two hpris cf sheep ;yere evaluated, one 

### iron 3,OCG to 

### 7,OOg head, and :be ather numberin5 

### 'rcm 

### 2,COO to 2,500 head. 32it (sheep) c3rcassss were injected ~wich a solution of 450 grams 

### of 

### iiCL or 225 ;rms ofsodium chiorid? hi in 1 its or 3ai:s 'der? ?iacgO in areas tnown
-' t3 be Frequented by coyot~s. Iner? were 

### a subs~antial number 

### GP kills in

### Herd Xo. 1 during the first seven 

### weeks cit5,e study, followed by 2 marked re4ucrion during the rernaining 11 <r/eoksof she study. The 

### use of YaCL 

### fcr a ~eriod of 

### time (3ftzr ,,veek9) cn this herd was 

### for the purposg aP having a control during which time it
was anticipat2d that kills by coyot~ would iccr~3~2. This apparently dfd not happen. 

### In lierd No. 2, heavy 10~52s occ~rred during 

### the first week of the study followed by 

### a dramatic reducticn in kills thereafter. According 

### to Dr. Ellins, this icdicaced 

### chat af~er ancounrers with LiCL laced baits, aversigns 

### to carrion baits


### were established in the coyotes and that these aversians were transfzrred 

### to 

### Iivesheep, thereby inhibi ting predation. 

### In the second year of 

### the study, which ran from 

### August 1976 to April ?977, 

### three herds 

### of sheep 

### were tested, ranging in size frsm 1,500 to 3,500 head. Coyote predation was considered 

### to have Seen reduced 

### assheep kill; shan cgyot2s 5n sne of the herds. 139. Aizhougn 

### Dr. Ellin; ccnc2d2b ;ha; :he prcper csncmtr?cion of 

### LiCL was critical in that the aversion develcped might be 

### to LiCL rather than to the prey (sheep),he was unable 

### to say precis211 what level of LiCL was nectssary 

### to develop an aversio~ in :oyo:2s to ;beep. 

### He ackncw1~Q;cdthat che cacczpc of avgrsive cznoizioning
was based on the assumpt'on ?I:srna:s faod SCIU~C~S for cgyc~?s we?' availablz, that no att~npr was rnade ~o ?valuate these factors in Antelope \/allay,cnac tnere was not a clos2 corres?oncenc2 be~crzen ;he tiine the ii CL Saits \were 71aced and a decreas2 i n 

### ki1; s

### , chat ic


### was assumed tha: ather coyote control measures (trapai ng

### , dznning and shooting) renained canstzni and that :hero nigh; be other more suitable, less saline or strong tasting chemicals rhan 

### iiCL. Although four ranchers prticipating in the project signed statements to the effxt that they considered the taste aversion program to 5e
a useful method ofcontrolling coyotes and reducing ?reda:ign, tney reius2d 

### to continue the crogra;n 

### on their own oRce the study .,vas corcpleted


## . 140. Testimony as to 

### the ne~rologicalSasis for flavor or tasc2 aversive conditioning was given by 

### Dr. John Garcia, Professor of Psychology and Psychiatry at 

### the University of California, 10sAngeles and a witness for 3efenders. Dr. Garcia has conducted extensive researchinaversive cond:xic~ingand :ne neurq;(;~yof 'sarning. ~e cor1sicer-2~ :nax c2st2 a\ie!-s1ve :=nai ::sj-,' r,~ +ids 3 

### ,i3312 2rada-fi

1' -, r ccnxrol alc2rnaciv?, ass2rting tnat gr3cacion !qas 

### 2asicaIly a feeding probl~,'f~ and that bo?h laboratzry and field ;cudies denonstrated the promise of taste aversion conditioning in control1ing predztory behavior, 

### He 'esti fied that tne 

### dosage of LiCL should be ax cuncsntrations nor detec~zbiz 3s salt by tne coyote or the aversicn l~ould be ta the ;a?c. 2e indicated chat a 15/ 

## - proper dosage would se .12 or .15 moiers, fhe quanci

### ty of NaCL present i

### n naturai f1esh. A1though he considered taat the fiela 

### stuaiss by Qrs.

### Custavson and Ellins d~rnonstr3ted 

### thar aversion conditjoning could reducz predation, Dr. Sarcia recognized ~hac furrner res2arcn xas necessary 

### to serfzct the ~xhnique and maks ic
more workable for ranchers 

### to irnplment. The ces1s by the F1dS of the US? 

### of diethy1stiibestrc)I 3s 

### an antif2rti1ity agent or reproductive inhibitor have previously be9n mentioned (finding 101)


## . A report on these tzsts indicates thac the study ar3as inTexas and Yew Hexicg 

### were ~reated with tailow baits containing stilbestrol approximat2ly cne month before the peak of the coyote breeding szason. Difficulties with coyote acceptance of 

### the baits and liigh reproductive success necessitated 

### a change in



### Is/ A mole 

### is a unit 

### based on molecular weight. It is 

### not clear 

### that 

### zeconcentration recommended by 

### Dr. Garcia corresponds with that usec by Crs. ~uszzvsor 2nd 

### t: !i~s 

### :n ~~21.2 :=z::,achi2ve mark2d reducxions iiroproaucti./e succ2ss and itwas c~ncluded that better delivory sysTems of juch baits 

### were needed. Xoreover, because stilbes~rol exerts its ;rimary eifecr on the 

### female coyot3 during a relatively short period of cine, deveio?ment of other antifzrti1 i~y agents was r~ccmenaed. ,Nr. Conno11

### y (finding 133) t2stified thar becausz 

### of these and other ?rob1ens, studi2s af 

### .anzifertili

### ty agents by the FdS haqde been tzninatsc!. 

### Dr. Noman L. Ga~zs,!/eterinarian and Assistant Dean of Vexzrinary Xedicine 

### atWashington State University

### , a witnesi fcr 'Xycming

### , i~c 31

## . and formerly a rzs2areh veterinarian at 

### tne USCA Sheq 

### Experimen; Station, Ou~ois, Idaho ~2stifizd that ~sts on ;he 

### conzroi of CG:JGC~S by 

### use of r2?rsductive inhibicors +adnor be$n succ2ssful and had been discontinued by USDA. There is no other 2vicence in the record as 

### to che efiectiveness ofreproductive inhibitors in reducing predation. 142. 

### Mr. Connolly testified that the use of repellants as a ceans of det3rring coyot2 actacks 

### on 1ivestock have not keen develo~ed to the point of practical field application. Dr. Gates (finding 141) stated 

### that evaluation of all chemical; claimed 

### to have repellant properties 

### as to coyotes, e.g., plictran, 

### crude extract of bitter sneezeweed, extract of red pepper and decenovonillylamide resulted

### --\ 9t-cmijz inreducing jheep :css?s 20 

### ~redacars. ,Yr. 

### Oeviin (finding 21 

### used 

### a r??el

### ianc s2ray 

### "Sheep P?rfurneYH ~dhich was ap~aren~iy succ~ssful in repelling 

### or det2rring coyots atcacki 

### on sheep for


### an 12-day period. Cnce 

### the effects of the substanc2 wort off, 

### Mr. Rev1indeclined to 

### use itagain 

### because he 

### was cmcerned about possible contamination of neat and wool


## . 143, Guard dogs, l,vhich are 

### tz be distinguished 

### frsm cogs us2d for heriicg and gathering livestock, have apparently Seen us& in 

### Fursqe and Asia to 7roi2ct s

### hee? and goats from predators f~r hundrds of 2ears. Guard dogs perform their function 

### not so much by at-cacking ~rm!ators, but simply by their presmca dererring pradatars from 2reying on 

### lives~ock. Common jrends used as guard dogs inci~ci2 cne Gr3at 

### Fyrcnens (origin: Franc2 and Spai

### n)

### , Komondar (origin: juncjary) , Shar Planinetz (Yu.josi,avia),/.tero,ma (

### Italy)and Korabash anb Akbash (Turkey). According 

### to Ms. Catherine de la 

### Cruz, a Sonorna, California woalgrower, breeder of Great Pyrenees 

### dcgs and a witness for Defenders, these dogs share numerous traits: cney remain aloof 

# - e 

### frcm strangers, 

### ar? not overly responsive 

### to human a~~xcion, prefzr the company of sheep to that of humans 

### or other dogs and 

### are not overly responsive 

### to verbal commands. 144. Ms. de la Cruz 

### has been raising and training Great Pyrenees since 1957. She has placed guarding dogs with ranchers in several states including California, Canada, Wyoming and Texas. She regards 

### repeat73 nJ V, 6-t c I (0 w -A. rt C P' C1 -1. 0 3 (I, C D rt 0 C) h c> 0 9, 0 -5 0 V, " rt 3 a, rt CT m 0 P, c m ID 0 -11 rt m 3 TI ID -I a, 3 m 3 rt 0 -i1 UI ZI 0 c 2 n CT m 3 m 2 n. m L1.

-A. 3 i -J.rix 0 tt If m -5 7 w 3 n '3

' C) 5 0 7 10 (I,

PI fl a D n 

### 2. < 2, rt -1. ID ul

u, 

# -- 4 m V) 3 0 C -1 a 3 0 rtUrn I (0 u3 P, I n CD a Iy (I, P, U -4 0 n 3c 0 -h Ct- -1. 3 m u n, t7 Cu C V, 0 rt 1 CIJ -1. 3 -1. 3 cf] C't 3 m ci 0 a Um J P, < 2. 0 3 C+ 

## 8 P, i a Et -5 rD Ln 5 m rn -u 4-1 i3 i -l ID t7 rt IU CL

u, 3- ID L= (I, C DJ -4 ---I v 'U 9, n 10 m 73 C 73 V, 

### 5. it 3- 0 0 DJ rt m a z 3- m -i m rt S rD 2. -a cu n rt -1. < -1. 9. n) Ln C) a, zl LT m 

### 2 0 LA m -a ,<

. 0 CT (I, CD -3 

### -= ID a 61, 3nCu a u3 -5 (D tn LA 2. < tD U) D -..A IU (I, 

## -

- 1. .

## - -U c 03 I n (-1 '0 IU -1. Ln. i (I,

- m (t iu -3 (U 3 '< (I, Cl
,- rb \ -2. u1 0 -11 rt f -A. 01 3 n, ct. a a rv 11 yu kt Zl 3 rl a a, LX C* IU PJ ,-I (I, rt

rd ro c: rD (I, n - (/I 3-

CU (I,135 zonths cf 2~2 2nd has r~~73ccd 

### :r rcfdnd2d :he 

### ;drc,~as~: 

### ~rjcs cn 1

115. 

### Ms. de ?aCrl.iz char;s $332 ezch f5r h2r dags and sstj~z-~d ~ke zfinua: cast for food, veterinary care, aegreciaxicn, 

### ?tc. at5250. :he considers rhe average useful 1ii2of a Grzac 2yrenees 

### to be fran six
co eight

### years following a two-year training period. 

## - 146. 

### Dr. Narion J. Levy, ?roiessor of Soci013gy. aand Internacicn~i Affairs atPrinceton Uni1lersi~y, 2nd his wife Joy, rajse Xcmondornk dogs as

7 fir- 

### a side1ing. Thny obtained their firs: Xamondor in I 501 an6 

### cver :he years have raised about 

### cen litters or approximately 

### 60 dogs, af which approximately 15 have been pldceti l~ith sheep 

### or goat ranch2rs in the Unit2d 

### Scalss and 'Canada. 9.L~vy t~st'fied:ha: '&hile guard aa~s 

### &ereextremely territorial and flouid ~2nd 

### to 

### fn a particular srea ii they knew 

### the Soundarigs, they a1so ilentifi?d I .I wich 

### the l-i'd~~t~~i< and noved with them. Ye stated chac che dogs should be trained 

### never co play with the 1ivestock, co 

### suywi~h the livestock and io know 

### their territory, buc 

### that other+iiiexhey should be given leeway 

### to follow their instincts and 

### nake their 

### own decisions. He assert2d that 

### the dogs need a minimum ofrnainrenznc., but that they should be fed 

### once a day and rsgularly checked for injuries, health 

### problens, flies, ticks, etc. 

### He testified 

### that placing 

### a dog with 

### a proper owner was critical in 

### that the ultimate


### success depended partly 

### on the individual dog, 

### but even more on the 

### personality of 

### the rancher. 

### Or. Levy indicated 

### that people who., . , , cnaz they did 

### not hawe so do anything fcr he dog ce 3 succ2ss=u! suardian. 147. 

### Or. kvy 

### ,&asof the opinion that guard dcgs werz generally 2fS2ccive inreducing predation. !e stated that he and his wife had not had any complaints from ranchers with whom xhey had placed logs, that they had not had dny dcgs r9turned and that their experienc? :vas consi

### stznt ~ifh surveys re?or;ed in 1itzracure co cne effect thzc the majority of ranchers using Grat Pyrenees or Kcmondorsk for guarding livestock cons'dered chm goad ca excellent in reducing predation. ile testified thac an effective guard cog $kasparcly


### a question of training and ~arcly 

### a queszion of maturi

### ~y. 148. 3r. zc? Mrs. L2vy charge 

### $6CO 2ach for dogs chat are ~f "get" quality and up 

### to 38GO for dogs 

### that are ccnsidered outstanding. in an I article agpearir,g .in the Oecercber 1981 issue of the National Noolgrower., 

### Or,Levy cautioned against exaggerated claims as to the effectiveness of guard dcgs, chat not every dog wouid turn 

### out 

### to be a marvelous guard dog and tnat not every farmer or rancher can properiy use such 3 dog even ifi; xatures we1,?. 

### !?e ?oin%d sut :ha: Koniondorok did not fullymature until they were at least 

### three years of age and 

### that until the dog learned 

### the rouzines and duties expected by itsowner, itrequired supervision and a great deal of patient attention.Shee? Z~$eri~enc Stasion, Zu~cis, Idaho, 2nd 3 ,qi:ness for S2A, 

# - + 

### has beon involvea -~ith reszarch 

### on the 

### e~rxt~veness of guard 

### dccs in reducing preua~ion sincs 1977. Of 63 dogs involved in -,he study, 45 have actually been tsstsd sufficien~ that performance data is

, availab12 (21 Kornogdor, 18 

### Great Pyrenees, 4 Ak,bssh and.2 Snar Planinetz)

### , :he others i,ejng considerzd 

### too young. forty 

### dc~s hay. :been 

### xes~zd su?ficient 

### thax subjective 

### ratings could be 

### zssigned: good-dog gecerally 

### regained near sheep, predation I,ras markeaiy reducza or kept co 

### a minimum and problems )wereninor in nature.; fair-dog showed ptential and would probably improve wi

### :n exDerlence and maturicy, ~radation 

### was somewhat re?rsducea 5nd Se~eSi 

### ts cuz;.!e\ cnea tne problems; and poor-no appzr2nt 'nfuence 

### zn ?redacion, dog

1 m exnibi r2d undesirabie behavioral traits and problems cuxltieignea <he 

## - benefits. I1,~enry dogs 

### -werera-lld socd (7Karnondors, 

### 9 Grzai ?yr?nee,s, 3 Akbash and 1 Shar Planinetz), 15 dogs were ratrd fair (7 Kcmondors, 8 

### Great 

### Pyrenees and 1 Shar Planinetz)

### , and four dogs were razd pccr 

### (12 Komondor, 

### 1 Great Pyrenees and 1 Akbash)

## . Seven~aen dogs failed
a 

### test. Howevsr, seven of 

### these dogs were successful inother tests. 

### It Nas concluded that 

### more mature and experienced dogs had a greatsr likelihood 

### of success and that 

### a majority of dogs could perfom successiully provided they were 

### tested under conditions suit2d 

### to temperament and ability.

### - saven of the 12tests, z~recti~/enesi gf cogs in ~,vo of ;h? 

### tls~s
was questionabie and in xnree of 

### me issts dogs had liczl2 apparlnt influence 

### on the number of shee? killed by predators. Kcrnondorok kerc 

### not as succ~ssSu1 

### on rangeland as 

### on pasTuros, 

### while Great Pyrsnees appeared to be equally succassf~~l cn rangeland as 

### on "ncod pastur~s


### . 151. Dr. Gr3en costified rhat )whileno special ski11s were rquir~d to
rear and train 

### a succ2srful guardjng dog, ~atience and persistencz
over a period of aTjeast a year may be required inorder fcr 3 icg 

### to be er'iecti!;e. He 3s;erted that a rzservoir of trzined dggi not availah?$2nd that guard ccgs zould not be vsewed 

### as 5 n~idlj deployable fom of predator con~rol


## . He further testifix! that guard dogs 

### were not free of problems in that they mui; be ;nte:r.ied into the sheep operat'on, that they may harass, injure 

### or naim livescock they were supposed 

### to pro~ect (two of rhe dogs at USSES having killed sheep and four others having been imp1icated in such incidencs)

### , :hat dogs may bite people, usual1ystrangers (three dogs at USSES havicg bitten 

### a person 

### atleast once) and that they are subject 

### to illness and injury. Dr. Green viewed guard dogs 

### as one of 

### a number of methods for reducing predation 

### on sheep, asserting 

### that they would not normally eliminate predation.es4;ina%d 

### ancuai food costs ar approximatsly 

### 52CO. Ze indicattc USSES had lost 11 

### dogs 

### to various causes including disease and :hat five had 

### been shot, 

### thremaliciousiy by 

### anknown persons, and -,:do by


### a cooperating rancher who 

### was loaned the d~gs for 

### test purposes. 

### k'e s~atzd that ncighbcrs and adjoining ranchers shou;b be 

### inforneb :hat guard dogs 3rz beicg used 

### so 3s z3 ?assen the chams they wi?1 be shot 

### as narauaers ifthey scray inta 

### a neighbor's 

### ?as:sr?. 153. As indicated (finding 11

### 7),

### Hr. Pfaif~,r conducsd 

### a survey giNortn Dakota ranchers using guard dogs 

### for predator control. Of 30 rancngrs 

### known 

### to be utilizing guard dogs, 

### data Iftas 

### collocted from 33, 

### :he other three having ?ups which 

### wer2 not yat beqng ils2d. Tke r~s~lt of 

### the survey ind.jcat2d a 93 p2rcenr reduction inpredation, This reduction was csrzpu~ed bas2d on 

### the ranchers' menory of :he exT2nt 

### 37 losses. The dogs (d? 6rea~ Pyrenees and 2 Komondorok) here uti1iz2d infenczd pastures in W2stern North gakoxa, 

### an arga 07 rolling hills, brush,.wetlands and 

### a large coyote population. The Great Pyrenees work~di

### n pascurzs of 10 

### to 1200 acrss guarding flocks of 10 

### to 1300 animals, with the typical Greac Pyrenees guarding an average flock of 590 sheep in

### a 250 

### acro pasture. Larger flocks and pastures 

### were generally guarded by 

### two or more dogs. Ranchers

- testifying 

### atthe hearing, who tried using guard dogs, did not nave good 

### results, indicating thax itwas difficult 

### to keep the dogs with the sheep, that the 

### dags became 

### sheep killers, or 

### that 

### the dogs wandered onto neighboring pastares and 

### were shot.or failure of 'A? 2:amb t3 wrse frcm fne ?we for cn2 ??ason 

### sr ano~her) 

### , dis2ase and other causss. Whi1e the ewes and 1an~s arz subjec~ to little or no predation during the ?eriod of confine~ent, predation can begin again 

### or continue once :he shew are rsl~as~d inngasxures or ranges and shod lambing is not an al;2rnacive mechod of reducing 7redati

### on. Shed 1am~i ng is 1abor inznsive. M~xove~, lunless ?roper prxaucions ar? taken l~i th regard yo clezniinesi confining sheep or 

### soars can acwa'ly increass :oss?s dus 

### to diszasz, parasicts

### , eIc.



## .

-- 133,in open range sicgations her?ers 

### ro cantrol and lsok afzzr the ;bees zreessenti

### zl


### . %hi 1

### e at 1easx as a theoretical iriatyzr addjtiona? herders could reduce ?redation lossss, ~xperienczd herders are in



### - * short supply. Testimony from ranchers is to :he ~~r?ct ;hat heri2rsi salaries range from 

### $530 to 5750 a month, but that rhe coca1 COST of rcain~aining a herder, i.e., for groceries, supplies, 

### etc. can be as high as $l,5GO 

### to $1 

### ,6a0a monzh. i56. 

### Or. Gates (finding 141), while 

### atthe USDA Sheep Experi~ent Station, tested electric fencing, referred to as New Zealand type, as a 

### nonle~hal method of predator control


## . The designation l.lew Z2aland refers to a type of charger whereby fence wires can be energized by 

### use of
a 12-vol

### t battery developed in 

### that country. 

### The charger is of high1. m fi,n - c~paci ty 32r~t :zi n? ge >:a; 12 -.bc

32s af 3.392 :r: i

### ,,,., !:31 ZS. Ibji raaiices che ?ossiki1i

### :y of in? ~nergized dir.5 2eing gro~:nc& J;, conTacE ,~i th vegetation 

### rhus render1~g the fence inefiec:i-/e. ,dhi;

### e placment of rarning signs is recommended, 

### Gr,Gates ex?lained tho-. the pulsating current made itunlikely that any person would be 

## -. electrocuted or injured by 

### contact with 

### ;he fence. oe configuration 

### of the fence t~st~d by 3r. Sat25 cons.istpd 0-f 12 31t2r~ativel;; 

### ". ener~ized and grounded *ires ;3 

### a neighr ofapproximately ;!\/e faez. 

### An additional energiz2d wire (;rip wire) was placzd 29 cn from :ae fence and 15 cn 

### above the grgund. The zltsrnatively anergized and grounded wires are for <hepurpose of assuring that 

### a coyccs atremp~ing to pass through the fence would r5ceive a sutscan~ial shock. 

### Tie trip wire is to pr2vent coyotas from digsing uncer ;he fence

# - 157. A1though 

### Dr. Gaies considered rhe tests were succesif~l , ne cauc:nnei thac such fences would not have universal application. He poinred 

### out that terrain may prgvent cons~ruction of :he ience in such a
manner as to preclude coyotes from passing under it. ;e siat~a :ha:

. * in sandy soil 

### a coyote could easily dig under the ience. :!oreover, i- <he fence was effective, the matter of hindering movements and migration 

### of wildlife mighr preclude its us2 in some areas. Fencing large areas could easily result in fencing in coyotes already there. Material costs were estimated at $1,000 per 

### km. Dr. Gates assertedpric2s an 

### avsrags r3ncher in icano could not nain;ain ;he f?nc?s he has, much less go 

### outand build new 'enc2s. Cr. Gates operats z 

### inall jheep ranch or fa* and indicated that 

### he has incurrd Ioss2s for the past three years. 

### 158. F,4S has field tzsxed alertric fencfng 2s a 

### aeins of predazor c2nr,rci in North Oakota and Kansas. In :he ?lorth Dakota tests, new fences
were csnscructed usjng a1tsrnazively char~ed and grounded ~ires. Coyote predation was 

### not defzrred dn-~il 12wires !were uszd zr-,d ;he height oithe fence was raised 

### to I68 cn, the conTigurztion 1ss2nxial

### ly bein? as-in :he fmce xstsd by 2r. Gates. Ail of chess tzsts 

### x~ere in smai1 enclosures, the largest being 3.7 3cr2s in 5iz~.In the Kansas tst~, electric wires werz ins~al: ed 

### on conv2nxionai woven and barbed wir~ sheep fences. The addici

### on of four and iive cnarged ivires eifectiveiy detftrred prdation. Again chess ezsts 

### werz an small enclosures, the largest being 1.2 acres. Haterial costs (1980) for the 12-wire electric fence were estimated at S1,580 per mil?. It is not clear whether this includes the charger. 753. The FN'Shas conducted a survey of ranchzrs using electric iznces 

### to protect pastured 

### sheep from coyotes. Of 37 ranchers interviewed, only 74 seemed to have adequate information 

### to permit a comparison of losses before and after installation of the fences. According 

### to these ranchers, losses to coyotes over a combined total of271 months-,,-

## --

## - 3 3ni 27 IZK~VSs2zj~n5 :~:2i<~ jf!Ssg. zf:?~:?s ins:ai?acion of 3;ectric f2nc95, 3~2r a serfsd of '22 ccn~hs and 22 iainbing sezsons, ~otal2d 51 sheep or 

### a ?d percen-, r2-C~czicn in losses. A reporr: of the survey noeed, however, that dam gathered
*, was based in part on opinions and stinates from memory, tnac psychologica7 factors undoub~ealy'played a ?art and chat stveral- ~anchers providing infcmation were 

### franchiszd to s2i1 i?ncins 

### xai~rials. The cnly rancher ds?ng slectric fencing 

### as a mans 2; predator control 

### ta appear 3: 

### the hearing 

### war Yr. 

### LinCon )Icn:gcrr,zry,


### a VcDonaid, Kansas, rancher and fariner and a ;vizness for ':iyomin~,~c a1

## ., lwho testified that sinca 3nciosing approxi~a~2i;i 25 

### acres arcund cis



### - ,- farmstad with e1c"ctr.i~ fe~cing in 1978, ne nadn'r. sa:~?r?d 'ny loss~s o? sheep or lambs 

### ta c~yotes witiiin <hefenc2d 2r3a. 

### 760. Dr. tlaurice She1

### ton (finding 

### 6) testified that while ir: was \d!;Ctual

### i)/ imoossible LO totally exc?udecoyot2s, it,was g2nerall~ poss-ible t3 exclude 

### them by fencing. ile indicated that the 1a;or 1ini~ations


## - were economic, pointing 

### out 

### that 

### pasturos in large areas of :exas
are stocked at

### the rate of 100 sheep per square mile and thac che cost of convenrional fencing around 

### a section (J miles) would likely cost $4,000 to $6,000 

### per mile or up to 9240 per head, ~ilich is many 

### mu1tiples of the gross income. Regarding electric fcncing, he related his attempt 

### toexclude coyotes from a 200-acre pasture in McMullen County, Texas inthe South Texas Plains, 

### an area of known high coyote density. Fence utilized was seven-wire, alternately charged and

- 

### -. . grounded, with 3 

### bzr3ed and :

### ;r:o >!<:resabsecuenzly added ts ,?ak?

was conduciad over an approxjmaie one-year pericd. Alfhough cniy three 

### coyotss were removed from the ~asture (by traps and us2 

### oia he1 icoptzr)

### , after installation of the trip wi rs, 

### Or. Shelcon tes~i fie3 that not 3 singieyoung soat was 'raised, coyote ki;?s being con?; rined in same cas2s and inferred in otners and :hat ih ?fens !was c2nsidered ineffective. He estimated rnaierjai for the 7ence 2t 

### 52,SOC. 11 Strobe-ligh~s,sirons and ?rapane exsiod~rs orzon Suns la4/& disz 

### been ;rsrsd ana <ti 1Iz4d inait~qpti to canirol or reduce pradaiion by coyctes

## . Tests by ihe FA5 uci1izing strabe-1ight/siren devlcls a1r?,nches inColorado, Idaho, Cre9cn 2nd Souin gakota, indicsrea reiucea predation over a period of 5 to idweeks aije\/eg 

### of tsn tests siies


## . The resul

### ts were csnsidered encsuraging, but additicnal work was considered necessary to idenrify stimuli, e.g., iignc, sound recordings, iha~ mosr effectively repel coyotes. Dr. Shelton testified that he had inesxigated the usa of lights under field conai~ions and found them totally ineffective. Testimony at the hearing ivas to the eifecr that cuyoces soon became habitnated 

### to the sound of expioders and even used them 

### to locate flocks of sheep. 162. Penning or corralling 

### sheep and goats atnight can be very effsc~ive in reducing predation. This practice, of course, has no effecc 

### on predation that occurs in the daytime. Moreover, the usefulness of this oracticn isconfined ta 

### farm flock operations as itis impractical 

### to pen 1

### arge f1 ocks under range conditi

### ons

## .lasz 

### 40 years, frcm a h?ghof 

### S6,67J,CCCin ;?A2 :a a 

### lsw of 12,220,200 i

### 6/ 

### - in 1979, i!icreasing s;ignziy ca 

### 12,941,300in :'?El. The number of shesp increased to 

### 13,176,G00as of January 1, 1982. P5r capita consumption of lamb and 

### mutton is approxirnatziy 1.5 7cuncis annually (carcass basis) of chich 3 

### ~ercent is 

### i~ported.?or c.?i ta ccnsunp~icn of 

### wool is appr0xirria~z:yone jound 3nnual1y 50 gerc~nt :f ~hich is import~d.Approximat21y 30 percznt of 

### the sneq inhe Unised Staces


### are raised inthe 17 nost western of 

### the 48 contiguous Statss Although approxirnafely '51,000 

### west21-n famerr anb r3ncher-s 

### raisz sheep, only 21,000 or 41 

### percsnt have comercia1 z?eraxi

### ens ,2f 

### 50 137

7-1 "CI more stock 

### snee?. 1nes3?r:duczri, nowever, 

### Jwn :early YJ gercznz of 

### a11 s~ock sneep in the rzgion. Laqe scale ?rcduc~rs lwi

### tn a i,OCO or \?ore stock sheq constitut~ oniy 6 perc2n: 

### 05 the proaucors, but accaunr for 63 

### gercent 

### of the region's stock shes?. 

# - 16J. Data on goats nave previously been discussed (finding 73). 

### lexas is 

### the princigal soat producing 

### state 3nd the najori

### ty a? ggacs prcduczd in

### Texas are Angoras, r3ised for their mchair. There ?re 2pproxirnately 800,000 dairy goats and 500,000 Spanish or neat-cype goars in :he United Stat~s. Texas 

### produced 9.3 milli'an pounds of mohair in 

### 1979 worth an 

### estimated $47.4 millionof which approximately $30 million
16,' 

### These figures are from 

### tables included with 

### the testimony of 

### Dr. grill, which 

### are based on USOA 

### statistics. Figures inother aoeumenes irl aiaence wnlcn are 

### also purporcealy oasea on US~A rLatisz1c.s differ slightly.I . 

### . -* -"n .

## . by T?.xas 9rXycers fr-n mna: r I n :220 8as bju.3 Ji !1; :n 

### . 155. Tesxjmony 

### cnzt sp-c?~un uiiiizatisn of auch sf 

### tae rans21anG in :he western United Srates requires grazing by cattle, sneeg and 50ati rather than a sing12 species 

### was given by 

### Mr. Robert ii. Xznslng, ix~ension iconcmi

### st, Texas A&M Univerii

### ty

### , Or. Czr1 :4enzies

### , Res,deni 

### Oirector 3f Researcn at the 

### Tmai P&iil University A~rj cu!iurai Reserrcn and Extlnsion C~ntar at San Angela, and by Or. dames 

### i. 3ownsJ ?,ange



## . - Ecologist, Utan State University, wl~nesses for !dycrn:ng, 2'. al. 1. was painted 

### out that cattle prefer grass, that sheep 3nd goat; seiact
some 

### grass, but that sneep select larse aounxi cf law-gra~ing nerhaceous plan~s (:orbs) 

### ,whi1

### e goats se1ect 1arge am,ounti oi browse. Sfleep and goats are abla ia 3rs;a rougher 3rr~in and arees which are more sparsely vegetated than cat~1 e. 5r~zi ng zat-cls

### , shee? and goats in the ?roper combinations and 

### atsuitable intensity not only increases the production 

### si animal praaucxs per acre, 

### bur tends to maintain the carrying capacity of the land in that iorbs nor. properly utilized become a weed problem and Drowse not pr3periy utilized becomes a brush probim. indeed, shoo9 and goats 

### can be used for the control of weeds and brush, thus avoiding 

### the use ofherbicides
or expensive mechanical methods of control. 166. Because sheep and goats can turn pasture and range vegetation and crop 

### 171 

## - residues into meat and fiber atrelatively low cost, the rising cost

171 Lower 1

### abor, machirrery

### , fuel

### , transportation, ti1 la~e 

### , ferti1izers, herbisdes, etc. required for range 1 ivestock production are sometimes referred 

### to as "cultural energy."of enfrgy in 

### reien; jedrz nas ~ajroved of steep and gozc ,Teais reiaciv? 

### ;o ocher inea;s 3nd of ,vooi znd 

## -7 mohair relative to iynthetici. According 

### to Ine U.S. Sheep and Goat industry Produc~s, Opportanity and Limitations

### , CAST 4eport No. 9L (May 1982), thepotential existi for increasing the production of sheep and goats in the major range ar?as by at least 

### 50 percen: ay utilizing the 

### brst ava!Iaale s8chnolcgy iin range livestack zanagement, by grazing areas not now used for ineep and goais 2nd by combining itaiternaxing the grazing of sheep and goats wich cacti

### e grazing


## . Or. Menzies (finding 165), who chaired cne cammit~ee t,vhichsuihored 

### the above report, described the 50 percsnt figure as 

### a reasonable assurnprion. 

### He ristified tha-. the ~rz2t-st 7otonzial far inproving efficiency was through lrnproving che percmtage of kids or lancs raised from 

### a flock. He ,das 

### of the ooinlon thac Increased procuctian and lower grices Far lamb and wool aould increase cansumprion of these ic2ms. 167. 

### Dr. Menzies nowd that among the lirnitzcions 

### on tne efficiency and productivity of raising sheep and goats were inf.ccious diseases, parasites, nutritional liseas22, poisonous plants, ava;ldbi?ity of labor, marketing problems, small size of the industry and predation. 

### He asserted that predation 1owers the efficiency of producti

### on costing both the producers suffering 

### losses and indirectly che consumer. He indicated that an often overlooked effect 

### is the inefficient use of land resources that result when high predation losses prevent the use of land resources by sheep and goats.1

## - ,2. 

### Yr. KensLr,~ (lin<ing 

### 153) ci2dsaca indicaziqg ;hz; in 13L3



### .._ ? 3.6 ~ii?;on neac gf carxlo, 12.3miiiion s;zc:< sneeg and 3.3 

### n:;;ion goats in Texas. 3y 1972, the fipr2s 'wer-2 13.5 mi11ion caczlz, 3.3 mi11ion sheep and 1.3' mi11ion goats a~d thatbby 1980, the figut-es were 13.2 million, 2.4 million and 1.4million, cattle, sheep and goats respectively. He asserred rhat the significant poin~ about che number of animals 

### was the change in speciss mix, and t!-12drastic decline and even ccrnpletz slimination of shee? and soats in some
areas. ;de deni2d chat the present pradcminazc~ af ca~~le nzrcers
was because cacti2 were more pro7itable. Se poincsd 

### out char. i :Idas not oractika? in~uch of Tsxas co subs~it!ito ca:tl? for sheep and 

### 181 

## - goars 

### on an quai animal unit basis, that 

### not only was the range
more suicable for grazing by cattle, shee? and scats ra:her than a single 5pecies, but thac such diversified operaticns resultsd in ;or? re1izble cask flow and werz in the bes-r; interests of the n,pera-,brs. He therefore concluded that the switch 10catxle \was due 

### to one or
more external factors over which operators had little or 

### no control. He assert2d that one of these factors was gredation. 

### He acknowledged, however, that low pricss played a cart in some ye2rs and thzt sheep and goats were more labor intensive for shearing, drenching, etc. inaddition 

### tobeing more susceptible 

### to predation. Among Mr. Kznsing's ducies as an extension economist with Texas ABM University isthe preparation of cost and return budgets for livestock enterprises. He

-. 181 - ~radi tionally an animal unit ofone cow and calf equals five ewes Ed lambs.sheep shoilced a. ne? rr-xrnof 513.32, t4t-11

### c;: r2 ~sssr:~~ t~c3bi :5n?d t2i: ?roduc2rz cou7d 

### not Ic~g colzrat? 

### zn aaciclcna; loss of tsn percent. 

### Se indicatzd thac this was 

### to count2r assertions in some quarters thar 

### sheep producers wers rnak?ng coney and could easily 

### 19/ 

### - absorb an additional t2n percent loss 

### to predators. 169. Or, 2awns (Finding 165) tesiif%ed tnac qreda5~n causes s2ricus scsncmic losses co nany ;rcduczr;, forcing 

### heabiinacnrnenc 07 ray 1ivestcck cerazicns

## . Fe ass2rtzd ti?a"ihese 

## : osses reach 1?v$is <ha-, prevent pr3per use 

### of range land 2nd arcper ucl1izac:on 07 'arase
resources. ?e s~atsd hat ~~OGUCSYS in ,\riloria, Colorado, ,Ycntana, New thlexico, Utan and rdyoninghave aoandonea oravoided ana goa; c1per3tij3ns because of sxc?,ssii~e ?r&ation ano :ha< many 

### cersons feel chat predacars and fear of :gsses ,Here a riajor faci~r jr~vent!n~ young peopi2 

### from enterins sneep or goat businessss. He iurrher testified that an encroachment of cayotes 

### on :he Edwards Plateau in Texas has caused many ranchers co abandon 

### sheep and goat 

### ?reduction and that other ranchers wouid prefer to uti1ize sheep and gcats for beff2r management and 

### brush control, butwere unwilling to risk major capital investments in areas of high predator populations. 

### 2e indicated that
some 

### banks and loan agencies wi11 no longer 

### risk capi

### cal on sheep and goats inareas of high predator populations without additional collateral as.security. According 

### toDr. Bowns, the result of 

### this



# -- ,-it-.. Ai:.i\;ugh ~c;~nsel !fur ~S?S~GE~S aS52r-Cd1 Siioi this 

### wzs senlng up 

### a "st~ruman," 

### Dr. Power (finding 174, infra) cited a study which purporredly demonstrated 

### that Idaho range sheep producers could breakeven at a 14.5 

### percent predation rate., 

### . 

### -..- L. ; ,uc Li 

### on iZC~ ~12s 21csrazions in the 

### aconczy

### , :zcr?zs2n- ;nloor:acc? I

cieaend 

### on and jupporr the agrical~arr? sector, and forced c5an;es i n 1iving conditi

### ons of rural fami1ies

## . Under crass-exarninatian, 

### Dr. 8owns acknowledged that he had not conducted any surveys of ranchers abandoning sheep and goat ocerarions or 

### declini ng co 

### mzor the business 

### becausz c~fpredation. He did indicztz rhat he had talked 

### to individual producers that have abandoned ~h2 sheep inlus~ry
wno gave predacicn 35 a ?r?dcm:nent fzctor in the cban~e in oper?zions. He was unab12 

### to give numbers or names of these individua:~. 173. In 1977, the USDA published 3 r29or-c 'Factors Inthe 

### Oecline of the 'Nestern Shee? Industry." In gathering data for the reFort, a si;rvey of a sample of ioner sheep praduc2rs in Colorado, Texas, Utah and Yyoming 1~2s conducxed. 

### The rzpcrt c:ncluaed that farm ?lock jrGGllC2ri 

### have declined r5pid:y in lunber beca?isemcre attractive cppartunities existed else'rthere for similar or better returns with less ~ime and labor required. Although iarge-scale operations declined lesi rzpid1.y than farm flock producers, they accounted for nost of -he declioe in sheep numbers. LGWprices for lamb and wcol, frustration with predation and restraints against strong corrective action, and difficulties in obtaining good hired labor were reported 

### as reasons for the decline. Financial returns were frequently neager or ni 11 and the majority offormer producers in Wycming were suffering operatfonal losses, i.e., not even meeting cash costs, when They discontinued production. The number of sheep ~roducers declined by?

### - 12 sercspx in 

### 1973, :ne year '~i lcwing r~s;r-icc;~,:s sn :no 

# .;

1z-? ;ax'czn:s, :he sr%a,:sc ;ercenz3se of rzd~c~jen i;nc? ,,is.
-, lnis 

### decline ;./as i'ollot*led by fur~ner 

### ieclines sf 

### 5 ;ers?nc in 

### ;371. and 70 percent in 1975. In Colorado and Tsxas, marl srcduc?rs stopped production in 1969 and 1970 than in 

### other years betxesn 1968 and 1974. The biggest dec: ine in numbsr of eroducers in Njcming and Utah occurred in 1969 and i

### 971 , respect::

### vely

### . Ceclines in zhes? 

### four states j i: 1373 were not ocr

### -, of 1ine ,r/i5h ehe nuxber of ~rsduc2rs disccn~inuing praduc.iian in otner years. F'r?da",on '+/as~iven 3s 3 significant faczor in the decision to discantinue sh~e? production by former rcducers inzach of the four st~ii~, a1;hougn sncn~ce of oood hirzd labor, lam^ and ~f\tcal pricos and age of the owner Irterz other significant re3mns. Pr?daxion was generally ,?or? of 2 problzn
i-the larger scale 

### farner groducars 

### chan to the snail operazlons. ! 171

### 1 CAty r2pOrTi in ihe record estinate 7rduc.r 1osses ~i sheep :s coyotzs 

### at$1'3 nillion a year, based 

### on estimazd losses of percent 

### to 8 percent of lambs and 1.5

### percsnt 

### to 2.5 percent of ewes ?roduc?d


### ax 1977 prices. Calf losses to coyotes in 1977 were 2stiimated 2: 0.4 percent valued at $20 mi1].ion. Itis indicatecl that total economic losses 

### to producers would nearly double if 1980 prices were used and 

### would nearly quadruple ifthe higher range of 

### estimated loss3s was used. Economic losses 

### to producers from 

### coyote predation 

### on sheep and calves in 1980 

### were estimated ta be 

### in the range of $75 

### to $150 mi11ion. 

### Dr. Terri11 concluded that annual average'producer 1osses

million. 

### He used 

### a multiplier of three inprojecting the impact of 

### these losses 

### on the economy. 

### Gee, eta1

## . esximated total 197a !GZZ~Z4 -' m n 7-V1 L n, V 3 V 0 L rl. n. QJ w 5= cn wl a X 0JI4' Kl 51 ?J -a CV 4' rd 

# - 3 V 1- rd U 

# - v3 C\I tl, C.r73 C .r-v

# - v v-- w 'r-'tL 3 x L r_ v7 'r +'3E rd ro cum

'JJ -c.>

, . I- rma, tntllr: 3 mI C' 0- w LZ 0 (I!- ,--- V' C 4 0 rd1 

### .. shoulc oe of?s?r oy expenses for shezring, ie~erinary f?es 2nd 

### iapz,yes, etc. iha~ waul@oineraije have been inc2rred 5ux for predaiion 10~~2~ of particular animals. Fixed casts for property taxes, pasture 1eases, or ranije permits do not ordinarily vary with death losses. #orilover, absenx extremely heavy losses labor costs in managing flocks would remain a~prsximarsly :he same. 

### Czsts for shearing, vetgrinary fees and supplies, 

### erc. wouh, of course, je lower for 3 lesser number af animals, but are not ordinarily siynificant. 173. inaddition to direct 1osse.s caused by ki11ing livestock, predation also resu:ts inindirect 

### costs or lossss. Dr. 3owns iist2d thesz 2s (1) r~duczd animal 7roduction 

### caus2d by malestaticn; (2):zduced production and doazh losses causzd by ~fforts fs ~vade ;oss2s (exariioils oarasite infes~aticn and smothered aninals resulting from clos? coniinernent) ; (3)cosi

### of supplmental feed for confined anjinals; (4) labor for gathering sheep scattered by predacar attacks and ireating injured 

### animals; (5) direct costs of control ?:for-s; (6) reduced attention 

### to other phases of fanand ranch operations and (7) inability or 

### unwillingness of ranchers 

### to produce 

### she? and 

## oats in
areas we11 suited hereto. He acknowledged that 

### to the extent restrictions were placed on the use of 1033, in the event itwas reregistered, at least some of these indirect 

### costs would necessarily 

### be incurred. 174. 

### Dr. Thomas M. Power, Professor of Economics, Chainan of 

### the Economics Department 

### atthe Uniiiersity of Montana, and 

### a witness for Defenders, disputed the vieur ta:ial: 

### greater ormore effective predator controlJ '+/oul d nec5ssari:;J 5er;er'i

### -, sheep ?rcrduceri as a ,vP,o? 2. +?,:oj fl:sd 

# - \ i 

### ou: that avai1abi2 daca (Gee, 2' a i 

### . here LC zhe ?.ff?cr '52: 

### 43 percenr of comercia1 ~roduc~rs inche weszern iJnif2d Sta~ss haa
no lamb 10552s topredators, that 67 percznt incurred no sheq losses 

### to predators and that only 23 percent had predator losses of lambs greater than 10 percent. ile explained that zn increasz in sup01y might %el 1 decrzase pricss sufficiently thaz gross revmce 

### to the 

### indus~ry l~ould be reduced and that in such an ovent, producers sufyering 1"Ltl2 or no predatior; would rec2iva icwer ?ric3s and no corresponding benef i 

### is. ?reducers wi th high przdacion 

### racts would gain at ;he expens2 of produc2rs with low predation. 'Ahether
an increas2 in _supply~ould, infact, res~i 

### t in a dscrzasz in ;ric~s depends on the imsizfvity of pricz 

### to the quanticy sola which is termed "~ri ce ilexibi 1ity 

### or price elasticity of denand. " "P7.i ?-- \r flexibility" is che percent~ge change in ?ric2 wnich will resuli. from a one perc~nt change in the quantity ofS2rsd for sals, whi:e "elasticity of demand" is the percznmse change jn quantity purchased that results from 

### a one percent change in price. Dr. Power stated that crudely one could be regarded as the reciprocal 37 the 

### ocher He testified that the price flexibi1i ty coefficient utilized by USDI of -.I7 translated 

### to a minimum demand ~lasticity of 5.58, meaning that a one percent decrease inprice l~ould result in 

### ;n increase of almost 6 percent inquantity purchased. He asserted this had never been observed and was unrealistid.

- - -7-- 

## .. -

# -

. 

## .. - I v2. ;r. 

### ?wersslcilazed a ;an :.\/el prizs ;..I; 21,- 7%; )f ,-j .5i zrLj irice '?astici:y ofdenand fcr ldnb of -3.1wn;-- I L~I 7;lesns zha: 2 ,?Re percent increase in iuppl) ~culd ~esul; in 

### a grercer i,+and ace perc-nt decrzase in the aric.. This decrease in pricz :vou?dincrnase demand by 

### less thdn one percent. 

### ?e citod other studies showing price flexibi1ity within the range af his calcuiations, noted that hi8 calculatjoni (based 

### on 7970 ;s l38C d2~3) 3ssdmed mat the denana for iamb was cansran:, ~ker~as the oata suggested demand :vas decl ning and znersfor? asserzed ha: his is~imated pric~ elasticity of-0.61 was an overt.siima~a. ie concluded inaf the demand 

### fur lamb was loss elastic than his ?s~imate Gr inelassic and thac increasel eWeccive predator cgntrol NOU!~ degress pric~s
more than enough to offset increased revenue 

### frsn :A? jaie afan:aa:s
i' 176. Cr. John Schaub (iinding W) testified that xhe ;r:ce relarionshi? for lanb &aselastic, i .2., that 

### an increase in quanrity mrkeced would 

### result in 

### a less than equivalsnt or corresponding dectease in price. He asserted that this conclusion was supocrted by 

### a preponderance 

### of the literature and tha; both jraducsrs and consumers would benefit by a reduction in predation losses and an increased supply of lamb. In cdlculating increases in revenue resulting from assumed decreases in predation losses attributable 

### to luse of 

### 1080 and increases in the number of lambs markekd, Dr- Schaub used a price flexibility value or coefficient 

### of -.42 (farm level, yearly basis) 

### taken from 

### a USOA publication 

### (Usman & 

### Gee) not in evidence. HeL; adhered to the !,j31~ that

# - ,qas L412arpropridi FT~C~ i:?xi bi!i

### ty



## . vaiue even ;:7cugii sucn $ialuesfor 2ther ccmon zea; itzrns ssch 2s
+ beef, 

### ;art and chicken 

### ?rere a', 1 greater than 

### one, inaiclting ~~nat 

### the demand was inelastic. %edefended chis result upon the ground that lamb as now so expensive, it

### was more of 

### a luxury or specialiy LIl 

## - item. He acknowledged that pricz flexibilitics change over time and tnac the data in 

### tne cired USDA pub1icati

### cn was cnli czrrenc through 1975. de ?ointed out, hcwever, tht 20. ?ower had not reported ~he confidencz inxarva! dsS0ciaxed wi :!-I ni

### s cceiiicienr of elasticity and thar 

### Or. Power's single estjmate did not indicare that sufficienx tests had been conduc~ed that jc could be consj2ered
a reliable est'mato.

-,-- 177. Using an estirnatsd average current lcsi of iambs 

### tz coyotes c; 3.2 percenc, 

### Sr. Schaub caicula~ed that a one 

### 7ercen: zedcc-ion inlosses 

### to coyotes ta 5.3 percenT would increase lamb production by 53,300 head and gross revenue 

### to producers by $1.3 mi 11ion. This calculation isbased 

### on the -.42 price flexibility value reisrred 

### to in the preceding finding. He defended the 6.3 percent es:i,~ated loss figore
as rea:onable based 

### on Gee, e t a l . ,

### wno derived an average loss to coyotes of 6.4 percent, even though he acknowledged that precise data


### on lamb losses 

### to coyotes were 

### not available. He also ackncwiedged that data on the extent 

### towhich 

### use of 

### I080 would decrease coyote predation were not available, but defended his assumptions as reasonable. 

## Ilj This is contrary 

### toa study cited in 

### the testimony of Dr. Power which is 

### to the effect that the price of specialty items could be expected 

### tobe 

### more responsive 

### to changes in supply.that reduciflg coyoc2 

### gr?d?z~on~QSS?Sxo 4.3 serc2nc NCL~~S 

### incr?as? lamb production by 

### 107,lCO head and 

### gross revenue f3ike?prgducers by $2.

### I 

### mii7ion. Reducing 1

### mb 1asses 

### tc~ 3.5 percent jxou1

### a increase production by 760,650 head and gross,incorne "L U.S. sheep clr3clucers by 54.1 mi11ion. A r'urTher reduction -,o 1.5 ?ercsnt IHGU?~ increiss iamb ?roduczfon by 267,750 heau and Sross 

### iqcome zo 

### ?reducers 5y 

### $6.5million. 

### Dr. Schaub indicared Enat 

### accsmpanylng ,d~cre2s2d losses to coyotes would be 

### moaest decr~asss in prices wnich wobld benefit consumers. A rzduct'on in coyots predation 

### from 6.5 perZen, 

### to 1.3Fercenr 

### would be 3 

### reduction of apprcxina~ely 77 perr2nt, which is unlikeiy even 

### under tile must octimistic 

### asscmpticns 2s La che eff~ctiveness of 

### 1080. Or. Jchaub asser~S, however, xna? zayotzs 

### >I prey 

### not only 

### on lambs, butJn caives, godts, 

### swine 2nd 7cuitry 2nd thae these estimates should be regarded as 

### a lower bound of potenrial gain 

### from rlduced predation. Such reductions in coyot~ pr2darion xould hardly be costless and thesz cost: should be deductzd in considering overall benefits. 178. 

### Dr. Schaub used sheep production budgets prepared by the Cooperative Extension Service, Colorado State University, in 2stinzting inpacts of the use of 1080 

### on individual producers. 

### He indicated hat ic
was unlikely that fanflock 

### operators would benefit to any appreciable-. . * range lambincj wou: d 70s; 1ikely b2 :he pri nci?a1 bener;ci ar;2s Utilizing Csoperative Extension Service oudgets, Dr. 5chaub calculztsd estimated economic impacA6of reductions in iamb losses TO coyozes for western Colorado produc2rs of from 0.7 percent to 3.0 percgnt for
a producer having 500 

### sheep 2nd shed iamoing, =rcm 3.3 7erceni ts 2.4 jercsnt for 2,WO sweep ,di:h shed 

### lacbing 2nd ircm 1.5zerceni rs 12 percenc for 

### a producer naving 2,400 sheep and ranas larnbino. fccnonic irnoac~s 

### werc also escinat~d 

### for an Eastern Colorado probuc~r naving 

### 2,GOO sheep, shed lambing and 

### an ssxizatzd reduction in coyots loss2s of from 0.5 percent 

### to 2.7 percznx. In doing 59, he made csrtain assumptions, i.2.

### , thac adaitional iambs wouid be nsrkec2d for slaugn~er, that feed, travel, and hir2d ldbor costs wuld incr?as? atths average 2we rate contained in 

### the ori~inai buagec and rhac range and family labor costs wculd be constant. Gross inccme for the producer with 2,400 head utilizing range lambing wculd increase from $1 ,845 

### to $15,454 depending 

### on the magnicude of 

### the r2duction in 1osjes to coyotes. ?roductisn COSTS could increase from $707 to $5,925 resulting in returns 

### from predator control and tomanagement increasing from 91,139 

### to $9,529, Comparable increased returns for the producgr with 2,400 head of 

### sheep utilizing shed lambing were $1,217 to $5,300, while production costs could increase from 5539 

### to $2,310, resulting in returns from predator control and 

### tomanagement increasing fromi

### 29

C r ?-. I ~co, ic 

### 52,gGC. F.7 354 ,:per,:+$?, ;?:ji ::::c? C~U?-J

i^ increase from 5317 ;o 

### 51,250,prcducricn cosrr cauld ir:r??ie 

### , ran 5107 

### to 5429 and r-eturns frm predatar csn~rai and :c aanagsmenz could increasa from 

### $210 co 5331



### . The astsrn Colorzdo producsr :uas assumed 

### to operace on privaiz land and to 

### have lower predaiion rates. 

### For this operaior, gross income could increase from $822 to 

### i4,2&5, production casts could increase from $533 ts 52,756 and rsturns frse predacor 

### control and to nanaFemenr coxld jacrease irom 5288 ~3 

### 41,189. None of these estimates include increases in c9s;s for predator control. Dr. Schaub :2s:ified thar tnese eszlmates were for losses consicered 

### to be average 

### or re?resen~ative, and that lik? all averages, ih~y could severely underestirnatz rhe financial impact

### on individual praducers suffering high 7redar:cn and thus oe rnisieaaing. 179. 

### #r


## . Bi11 D


### ..Sneed, President of 'i 

### rst 

### Cole~an 'la~i onal 3anu of Salewan, Texas, a rancher actively engaged in raising sheep, soars and caitle and a witness for Yyoming, et a1


## ., tzstified that his bank had denied requests for loans 

### on sheep and goats (apparently using them as collateral) because of coyotes. 

### He explained that there kere certain
areas of Coleman County, which were heavily infested with coyotes and that if land jn 

### one of-those areas changed hands, his bank would decline
a loan on 

### sheep and 

### goats in one of those areas. He asserted that a number of ranchers in

### the County had gone 

### out of business because of losses 

### to coyotes. He acknowledged that there were ocher reasons fordata indicating that in 1,276, tiler? ;wer9 77

### ,,ZOO2eies in Colerzan County and chat by down that there werz 204 sheep prcducers in the County in 1977, bur only 165 in 1981. He contended that the sheo? industry was vi xo the County and,thatmany areas 

### were more suited to sheep ?robuction or 

### a conbination ofshee? and cattl

### a production rather than just c3ttl

### e. 

### ik said that on a ;articular 575-acre iease, he Idas unable to rtin sheep due to ?redation by coyo~s 2nd that he (was only one of ,~zn;/ fac2i by that proole!. :e further cmtenced thar only ;qith the reinsta~ement of Compound 1080 could coyotes be contr~~lied and ncney returned to the pockets of the producers. $.nother side of che econornics of prsdatgr control was presen~ixl by 

### Yr

## . Robert C~r~entzr,


### a Drews2y, Oregcn czttle rancher and a witness 

### for C~Tanders. 

### Mr. Carpenter has not suffered any livestock losses 

### to predators and was highly i ndignan

### t at

### FWS ADC conx~ol ooeraxions

### , because he considered these operations deprived his sons and others ofn29aed income from the sale of coyote pelts. 180. 

### Mr. Charles Howard (finding 

### 71) estimacsd that his total income from goats in 1979 was approximately $28,0CO, while his predation losses to goats totaled $35,619. This included direct costs of $14,637 comprised of $10,657, for loss of goats and mohair, $1,470 for travel to 'pastures to pen goats and $2,520 for ranch expenditures inthe control

of predators. Indirect costs included $5,400 loss of adult goats co parasites and complications, $3,600 loss on goats sold because of. 

## . croductian ass~r~edlj Sue ~2 penni?~, $;3,413 In 1~~32s ~f 

### tics acd


### -. xohair 2nd 

### S823 in

### veserinary f2es and 'rugs. Infse figur2s 

### jc: rzcz and indirec-c coscs) tocslea 541,979 

### from which was subtractsd S6,jEO for 

### expected normal 

### iasszs ofadult goats, kids and 

### nonair.
issue 5 181. 

### Mr. Cannolly (finding 133) testiiisd :haz intact, ~nbr3kan 

### cgllars ci:

8. 

### not pose an ?nv?rcnnenial hazard and wer? not a sijnificanc hazarc :o collarad 1

### ivestock. In the FWS field cests lwich ;he toxic 

### ccilar a 22,' 

### - total of 313 collars were used, of which 

### 25 :~erl rzccverzd aft2r having 

### been punc:ur.d by coyot?s, four zore collars wera probabl; punctured and not recover2d and 14were lost. In addi~ion, 11 coi1ars ;rerp,

### acciden~a11 y punctured. ,A1:nough :,he repor? of 

### the avaluation 

### of these 

### r,zsts by /4r. Connolly ackno:v?ed~brha', the hazard posed by 10s;: collars 

### Idas difficul"Lo oOb.ject.i5~e1j/ assas, i 

### r.
was pointad out that 

### the collars were nost 1ikely to be found by tne livestock owner, who would be aware of the potential hazard rather than 

### a third person unfamiliar therewith. 

### Itwas further pointzd 

### out that the principal danger to 

### the finder would 

### be from opening the collar and taking the lC8O orally, which he would do only if he failed

221 The actual number of collars used was 151 

### small and 94 lar~e col1 a;, the.313 figure being the 

### result of counting separa~el y col1arr used on more 

### than one 

### test. Small collars contained approximately 300 mg toxic solutian while large collars cantain twice that amount.. . that a chila 7;;;Snr:var,i?r jqr-3 

### a ?aszure, fino a ?urc:ur?d 3r iz:;ti 29 collar, get :he toxic soiuxion on his hands and then int3his nzuth. \hi 1e his possibi1ity cannot be ruled 

### cut, itis highly ~nl ikely. 

### Mr. Connolly recosnized that lost collars would eventaally deteriorate, a1lowing 

### the :oxicant co enter the soi1 where irwould be detoxjfied by bactsrial actisn



### . The time required for detoxification ,vou!d vary with he amount of toxicant, soi1 type, temperat~rz, zsc.

### , jut studies

1 hP summarized in

### Aczert, wer? to che effect degradation 

### :f Conpo~indiudO in soil required from 

### 0 to 11 

### rreeks. In sen tests with eigh~ c3llared lambs using dye rather than Compound 1080 in The ca?:ars, scread of the dye afxrthe co?larsNere punc~ured by ccyot2s varied be~~een

-L "A 12 sq. it. to 300 jq. fr,. d'th 

### the aversge being i38

## jc. f:. Sc;.=,.-. of the dye depended an whether :he lamb 'r/as dcwn or inoving a: :he I time xhe cgllar was puncturad, Ixwas estimatsd tha: an 2v2n 

# i1
distribution of Compound 1080 over rne average dyed ar2a of 138 ss.



### ... it. wouid resuit in conczntration of 2.2 ag per sq. ft. ;neproszecc that such a 

### low conc2n~ration would causz serious environnencai damage
was considered remote and no such damage was obszrved in iieid 

### tssti. In initial tzsts with 

### the collars in Idaho, some of the collars lsaked and six collared lambs died. Although 

### Mr. Connoily initially thought 

### the lambs had absorbed the toxicant through the skin, he subs2quentiy concluded that 

### the 1080 solution dripped into their mouths and that 

### the mode of ingestion was oral.

d

### cr,crns. Jo 2v:zerrce cfsilcn ?ur;czl;ras :vas coszr1/2c,sn sn'nal s ~j;h puncUr2d collars 3r cn 

### che 

### ground 2ven r9oUGh zhe :oxiz joiusi~n con~ainsd Rhodamine 3 dye 2: a safocy indicaur. 

### Anorher rzutz of potential exposure is the carcasses of csyotes poisaned by ?uncsuring 

### toxic collars. Gniy turkey vulxures appear 

### to 3ave scsvenged my of 

### .he coyotes found during 

### fWS cesxs :vi ~h the :oi 1

### ar. T8~rk2y 'iul

### tutes

### , black 

### \tuitures

### , nagpi

### es, rzvens 

### , red-

### tai1 ed hdwks

### , car3caras, 3 skunk and a coyota Nere known to have scavenges c~~lar~d 

### 1ives:ock 

### killed by coyotes. Scavengers feeding on collared li~esiack 

### killed by cayoles cancencrased on viscera and 

### muscle tfssue racner Than 

### ~he eel1ars

## . 1Yr. Connol1y t2st-ifisd 

### chat he 'lad oever obrer.ie~ scaveng! ng


### on cne neck arc3s 

### 07 col7ar2d 

### ii\iest3c!<. ?ho-cos in the record of collared livestock heavily scavenged show neck ar2as largely intact. A1thcugh itis ?ossible 

### rhat there 

### were non-izrze~kill; fesa::frc from 

### usa Of 

### the collars, none ;Yas observed. 

### Xr. Connolly 

### si3~ecl chat if there had been any 

### substant~al number of non-targer 

### kills, they would have Seen located by 

### the intensive 

### searcnks 

### on che Charles %ward 

# - Ranch, Meridian, 

### rexss. 3ased 

### on these field observations, itwas concluded that ther9 was no reason 

### to expect significant poisaning of non-target wildlife r~sulting from the use of 1680 jn toxic collars. Non-target 

### deaths of animals suspected sf being poisoned by 

### lQ80have not been observed 

### to date intests with the 

### collars by Texas 

### A&M University. 183. As ~na~cated (iinoing 88), 

### SLUs containing id80 have not been extens~veiy 

### tested in the United States. 

### They have been and are being used in Sritish

### C;iumbja 2nd ,;us:r-j: la. 

### iar~e ;c?n~i iies 2ijimil?r s:rjchni ne cairj, ' I

7 -77 %erezjed 

### jy AiC ~rzar.r,ei fjr the csnirg; cay0t.s ;rior :2 ,Y,- (finding 

### 94). X!:houcjr! SL3s used 'n Srii<~ii ioidrnbia Ere avered ~3 minimize the possibiiity of targets consuming nore than one bait acd 

### tominimize exposure io nun-targei species, th2 aoplications for 

### the use of 1C80 in SLDs by Montana, South Dakota and Wyoming a~oarenzly do not envisage tha~ bai:i ltqillbe c3vered. 4. ?anaal1 (find? ng 125) test!fied tnat he was never inforxe'l hat strychnine droo hi::s jhouii b,e covered. lje furthzr tasti

### fi2d thzt it 'would have seen very difficult to do because ininany areas i here bajts were placed :her? weren't enougn cow chips and rocks were frozen :o the ground. Ye asserted that no one covered itrychnine bai5s ; 

### nc?A ynstanding 3 memorandum, datod Decmber 

### 15, 1970, that i: was 3urzau 701~cy :he Sai

### zr be covered. Se Idas of

### the opinion :hat 'her2 

### was no way to keep track of such bait: 

### or that such a progrzm ;;uld be prcperly

184. The exposure af3L3s :a non-target species &?ends, of ccurse, 

### on the rate 

### oiapplication. 

### ?lantana's application Tor re~isirarion of Comoound 1080 envisages 3.5 ng 

### of 1

### G80 in a IS-sram bait ,xith a maximum piacemenc of 

### 25 per square mile. South Dakota's application 

### is also for 3.6mg of 1080 in each ba?twith no iilore tnan t'tro hairs 

### to be placed at any one draw station and no 

### more than five such

/ stations 

### to be located in one square mile. Assuming maxiinurn usage,, 

### r,no,rz z-Q?~ 53 352 '32;~5 7yzz3;ii?shi3 csnr2.lnivgm-?rc;:j--a'_-l~ 1,3g cf 1CSO 

### cr 

### sli~nsly less :mn the 

### 1.5crms 39r 

### 130 ~OU~SS USC~C in 

### a ?arge 

### scaticn. 'Aycning 's appl

### icaci

### ;n apparenciy iqtsn~s chat th? 

### amount 

### of 1280 in 

### eacn bait 

### as 

### well as the 

### maximum applicaricn raz2 be left to 

### the judgmen?:of the applicators. 9r. :iiliiam suck, Professor of Vezerinary Toxicology 

### and Director of the Animal Poison Cantroi 

### Center, Gniversity of Illinois, lirbana 

### and 

### Dr. '/a1 I?. B2?sl9y, 20ct~r of Vetarinary Xedicine and Research ,Asscciate inToxicoic~y a: the University of I11inois

### , witness3s for Deflndzrs, kstified :?a: 

### Secause SLDs 

### wer2 designed for 

### more widespread use, chey were mcr2 iikoly co be more availabls 

### to domestic dogs and cats and use of SLDs could result in 

### the poiscning of large numbers of 

### thesz and other 

### snail non-target carnivores. Dr. Buck acknowledged, 

### however, rhat 

### a requirz

### menc tnat baits 

### be placed no nearzr than a ~i3e or mo from 2 home 

### or occupied dwei1

## ins would 1esszn the nazara co nese animals. 185. The contzntion that Compcund 1C8C is 

### a sel~ctivs poisan is bas& in 

### ?rinci?al par: 

### on differing leveis of s2nsitivity 10 rho, joison. Carniiores .rp_ ingeneral Tore sensitive 

### to 1030 than a;her s jet!es, while canines 

### are considerzd :o be 2speciaIiy susceptible theraf3. 23/ 

## - For example, 

### the 

### LD50 of 1080 for 

### a coyotg 

### has keen determined 

### tc 

### be 0.10 

### mg/kg, 

### whils that 

### for 

### a man is estimated 

### at0.7 to 2.1 mg/kg

23/ An 

### LD50 value is 

### a statistical estimate of the dosage that 

### would be 

### letxal to 50 percent of animals t2sted.136

-1 . (7; 5 -P4, 2-- and ;ha. for a scls2n eagle is 1,25tg 

### 5.C0

### -x/t,. J. 1 tu I Sui;s

1.5 g of 1080 per 160 pounds of bait, thac a i50-pound man wauid obtain an 

### LD5g by the consumption of from 47.6 oz -LO 142.3 oz and that a gol'den eagle (average weight 7 pounds) wouid recsive an LDS0 by consuming from 4.0 oz co i5.9 oz of such bait macerial. An LDlgO for 

### a coy0t2 has been estimated 3t0.16 ~~g/kg. ic is zcparsnt tha; the LDcO 

# - values fcrnan and the 23912 as neil as scter s?ecifs ar? 

# - not precise and have a cgnsiderable

## ranee. 12szsso 2stablish :hese values have obviously 

### not been csnducted 

### on humans 3nd Tne xsts 3r1 many other species including coyots and eac12s have 

### not wen conducted on a sufficient number of 3ninals cha~ a staciszjczl coniidence interval can oe zstablished. Inasmuch as the fcod consurnprion ofan eagle is approximatoiy hopounds a day, L ii clear that an eagle could obtain 

### a potentially lethal dose in feeding


### on 3 bait station. This is, of course, 

### also true of cther ncn-carget sgecies. There is evidence that the $350 valu? can vary depending


### on whether the god? gf administration is by a tallow bait or 

### water. Moreover, 

### Drs. Buck and Seasley (finding 184) referred to a study indicating that a median lethal dose of 1080 ac 22°C was 21 mg/kg, while at 8OC, 

### the equivalent dose was 4.5 mg/kg, indicating that temperature had a great effect 

### on the toxicity of the poison. 

### LDjO values are more likely 

### to have been establi ined in laboratori?~ at


### or near normal 

### room temperatures.

## -. ;usper.sizn of ;oe ragii;ra;i3n 2; ;oi~pcu,~; 

### ICaC) rr-g~r:::; ibr;ebait s~az-ians )was thaC :he ninihum number Fecessary co 

### achieve


## -8 effective cayote managenent ras f3be glac~d. ~nii Lvas jenerally interyreted as requiring 

### or penizting the pliicemerlt of not more than one stazion per township. %i:h the approval of the Siate Supervisor, up to tuo stations per cownship could be 

### ?laced wner. cerrain required adai~ionai pl3cementi inorcer i3 achieve needed controi. Guidelines issued by tne 3urzau further stazed 

### tnac :he
use 

### of 1020 large 3ai

### ts was a technique r5served for ar5as here other con~rol methods had not been eifecti~e in r~duclng cayoie populatjon to a desired level and where such use would have a

,.

## - minimum efiecz on oon-carget wildlife and domestic animal:. LTa selectsd size did net meet mess r?quirerneni;, 

### 1580 ,das not :s be used. 

### Hr. Randa11 (ifndino i 25)

### , nowever, :escizi2d iha: ln jr?cclce the number 

### of bait staiions pldced each year djd not vary signifiianrly and thai the stations were placed in nore or less rhe same loc~xions each year. 

### The tesiimony that bajii ~ers placed in aoproxinateiy the same locations each year was confined by Mr. Gene Chaoel, a Montana cattle rancher, 

### a former ADC employee of the NSand 

### a witness

. for the AFBF. 

### The theory of not nore than one large-bait station per township was, of course, that coyotes being 

### more rnobilo and having larger home ranges would be more aptto come in contact with and feed on the station while smaller, less mobile animals with

6 2 2 r i e A I IL, 

### ~lr. idoaaI asserted that 

### thrre..~lras no place where only coyotes lived. Hethat gany AOC fi21d ~ersannei cc~uldn'c isen~ify tracks 07 various species, and they had no data 

### on locations cf endangerzd species and ocher non-target animals. The rssulc was that ~aics wer? placed away from ~ater and on elevated loc3tions ,&her?the sncw


### -

# - would most likaly be blown or; and di~hour regard tc ,ion-t;r;ers. 187. Bureau guidelines also called for bai? sxations 

### to be ;iac?d as 13x3
as practicabiz in the 

### fall in kegping wich ;af?ty "i one5t-eaciflg mammals and birds

### , ?f7?cziveness in csn~roi 1ing damage, 3nd conditions ofweather and travel. 3aits were tobe removed as 2:rly in zne ;?ring as weather and travel conditions pemicted, a7ssr allcwing a suitable, bu~ ninimum ~ime for .xpis~;.:?, 

### In the~ry his $1irnicatxi

or mi~inized exposara to bears and oCQeriibernaiing aniflais. 1 

### Hr,Randal1 related that in many instanc;:~becaus? of ~he sgowpack ~t higher el~vations and the press of other duties, bait stations could - 

### not be rmoved until early sumer or iacer, which was long aizr hibernat'ng animals 

### would be out. 1%. ,As indicated previously (finding 1

### ;)2j, large-baits -were co 02 treated 

### atthe rate 1.6 grams of 1080 for each 100 pounds of meat. 

### Mr. Randal1 described the difficulties incbtaining proper distribution of 1080 inlarge meat-baits. He testified that even after 1080 was distributed7 ,- ,l -r in vials of 

### 0.3g and 1.6 g, i

### r: :vas iv~ossible 

### ts a'stribu:2 12; ,~;Lv -3s > ;f a srs,.;:?%/enjj zkra~~n e2c:? 

### ?sun:', 

### of m't. "= ,

## - C~SCY:';H! :he ?r,,irnsn: ~ssd, ;IC!ort3n meat pliii;D for rhe ?tir?os2 ~f 5~3ar ~lir! ncj hans

### , as


### a medieval method of application, and asserted thac ckbe

### o?ungars frpquently leaked and that the pumps did not work properly if usd in below freezing or 

### zero weather. 2e stated 

### that 

### 1080 had an affinity for protsin and would not penecr3te membranes. IFthe need?? hita membrsne, ita~torna~ically created a ho~ spot, i.?., an ar2a cfmre conc?ntra-c2d so1ut;on. 

### He indicat~d that even aStsr 

### :4GC fieid 

### persor?nel were 

### furnishzd scales, it was still nec2siary t3 estinat? the amcunt of bone, hide, 

### etc. in each ?crticn in 

### det~rniniag:he ?roper quanzity of 1080 solu-cion 

### to apply. He statsd hat gradua~ec containers hoil'd have Deen 

### of assistanc2 in~ixins che proper quantify, bux xhat such con,;-j.iners

### Were no; avaiiabi?. 

### :! 133. 'iith che zxce9t:on of Er. Randal1, tesciinony 

### from 3;1 ~ifnes~~s tine par-cicipated inor who 

### wera fami1iar wizh th~ 

### I080 baiting program
was to the effect th{lCdeaths of non-target species from the baits


### were minimal


## . Beca~se of tne charac12r-i stic iat.2ncy period fcr toxic effect 

### after the ingestion of Compound 1080, it is probable that xny animals and birds feeding 

### on the stations and receiving 

### a lethal dose would 

### not die in the imediate vicinity. The svidencz is that searcks 

### for birds and animals thought 

### to have been poisoned by ~he stations
were chiefly conducted 

### atthe time 

### of disposal ofremains of the baits and that these 

### searches varied widely inscope and intensiry. 

### Sy that;i rds 2nc dnjra!5. :ocu:c 3u:22u poiicy :ai l2d fcr :5e reporr' "3 

### of coyotes 

### as 3,ueli 

### as ncn-tjrger ;?eci?s fcl;nd in juch searckes, 

### #r. Randall i'ndicated tnar. this uas for 7ublic rela~ionj purgoses ~RC that thera was cacit understanding among field personnel ulth rihorn he was familiar that the actual magnitude of non-target deaths not be rz~orted.

nppr 1

### ca0 190. Aanda! 1 restified chat he i3rX10nl y fll;!Id dezd iad~ers ,,&-, baiis or ;he remains 

### of such s~acions.de explainel ihai saocers ~ould dig a hole underneatn :he station ina atzempt 

### to orag che zea: into ;he hole for their winisr iaod suooi

### y. Ye iia7.d 

### rba: in cne ioring as Jany as four dead badgers hould be found in one hole. 

### In conrras;, 

### Yr. Johnsan (finding :CS) s;ared ;hat he lad ooservea i badger living under 3 bait stacion hhich ap?eared 

### to be in ;cod heaicn and i4r. Anderson (ii nd-ng 

### 116) festifid :ha1 badgers frzquently burrowed beneath bait statlcns, spending their vinters there and us?ng the starion as 3 food source without apparenr ill effects. He stated thax he had observed this oersonaily 

### on approximaiely one-half dozen occasions and ;hat i r had wen mentioned 10him by others as we1

### I

## . ke attributed 

### an incident involving the finding of seven dead badgers 

### at

, bait stations in Texas 

### to improper dosage caused by use of insufficient water in treating the horse meat bait. The 

### LD50 for a badger is from 1.0 

### to 1.5 mg/kg

### , which indicates that 

### a badger (average weight 19 pounds) would obtain an 

### LCjO dose by consuming from 8.0 

### ozs to 13.0 ozs1080 residues were found in

### a sample iram 

### a ccndor, 13 golden 

### eagles and one bald eagle received 

### atthe Cenver Wjidlif? 2esearch Csnter.

L Tests 

### on one of the golden eagle samples *#ereposi

### zive Ior strychnine. 19i. 

### In the fall of 1969, the 3ivisian 

### of Wild1i?? Servic,?~ ;nsci:used 2 policy of including a iracerize in 

### I090 solutions 2nd r-trycnnine 

### arc? 

## - baits. Iissue samples of 

### a bird or aniinal killed by either of ;he52 poisons wauld fluoresce under uitravisiet 1ight. Accordirig 53 

### Mr. 8andal1

### , he same tracsrice *das pl

### acsd in strychnine and 1

### C8G baics and WE!7urpose of i-,ce !prosram was not ;,o nonil-or ,,diialif? killed cy :he baits, but 

### to be in 

### a 2osiiion 

### zo deie~a against cls<rnr

C I

### rom dog owners and cthers ~hos2 animals were pisoned. 'ihiie s:ill


### an employee 

### of the 

### EYS,,Yr.Randall coilecteu carcass3s OF birds 2nd animals which 

### he cgnsidered had been poisoned by 

### strycknine drop-bairs


### or 1080 and subjecred them 

### to ultraviolet ligh~ 

### in the bas2meni of his home. A table in evidencs reflects that 

### he autopsied 46 mammals (8dogs, 

### 12 coyotes, 17 badgers, 

### 2 bobcats, 2 pine martens, 1 mink, 1 

### skunk and 3 weasels) ofwhich 

### 20 showed evidence of 

### strychnine tracer and 19 showed evidence of 1080 tracer. Of36 birds autopsied 

### (I0 golden eagles, 2 great-horned owls, 2 red-tailed hawks, 11 magpies, 3 prairie falcons, 

### 5 unidentified hawks, 

### 1 sharp-skinned' hawk, 1reldtion 

### ra prcxlmiiy of 5~jis and orher evidence rather Than o: tracer. There is, of course, co doubt that 1080 bai: stacions and
r strychnine drop-baits killed 

## - birds and animals in addiiion lo coyorss. 

### Dr. Yagner (finding 10) res;i iied that thers. vas no derce of ~igniii~cani adver52 impacts on the ?opulations of non-targes s?eci?s from the us2 sf 1080. ?e assartzd that the loss of scme individuals
was not 2 sufiicient basis for detsryining acvsrse impacts 

### on the populaiion si

### a species. He indjcated, however, 

### ihzr therz aas nc evidencs cs Show an eiiect or lack :he~~oi 

### cn endangered or threace~ed species. 192. In 

### tests csnducted by <he FWS :s evaluate primary hazards of Compound ?

### 090,dogs and magpies were a1lowed 

### to f2ed 

### an the carcasses of coyote-killed sheep or goats with punctured collars. ?lo ill effects 

### wer. observed. In tests to determine the primary toxici~y 

### ~f 1080 

### to raptors, two golden eagles and a rough-legsed hawk aere each orally administered 2 mg active ingredient lC8O in 

### a beef ~a1 low bai;, approximately 9 grams in weight, each day for four consecutive days. Over the four-day test period, each bird consumed 12

### mg of 1080, which is equivalent 

### to 3.2 and 3.1 mg/kg for each of the two golden eagles and 9.5 mg/kg for the rough-legged hawk. After administration of the third dose, the eagle receiving 3.1 mg/kg showed symptoms of toxicity (grossmotor impairment, Fluf'.Fed feathers and loss of appeti

### t~)


## . Dr. Peter J. Savarie, Re.;ear.cil Plrarmacologistat the Denver Ui1dlife

. , Research Center and an 

### expert witness for the FWS, 

### testified that this32gl2 r3c3verea ?n 3bcu'l six 

### ia:/s ;ylizh no apparPnP side 2i53~:~


### cnac si~iiar syT;ccrns t(et-2 ,13c ~~s2rved :n ~9s cher ??<:a and rl:z

.7. * na:vic. inese rzsuics arc baseo solely 

### sn ocservazicn 

### 07 -,be 6iras. 3r. Savzri? ackzowledged :hat itwould be desirable to 

### conduc~ xorz tssts with a greatzr number of animals in order to fu: ly 

### asssss primary hazards to non-target species 

### irsm :he 

### use of 1083. 1'33. in ~ests to deternine seco~dar;,7ojsoning hazards 

### to rapczrs, 

### ;he

L ?do golden 2agi.s ~eztioned inthe primry hazard 

### tests r?! lrrac 

### to pre\~iousiy and a different rougi1-;2qgzd hawk ner? f?d grzuna ii;eat obrained frcm five 

### coyoies ~ach adninirzared an oral 

### dose of 5 .g,'kg ac~ive ingredient 1080. Coyo-ce 

### ineat was the 

### sole saurcs 07 f3od =ar

- * the82 bird; 

### over che ten-day period of the %ST, no food beins crr?r?d
on the fifth day. Analysis of the meat indicazld zhac i; concainea from 1.8rngjkg to 3.1 rng/kg 1080. Uneaten neat was retri2ved and weighed 

### to deternine consumpxion. 11 :ras der.ril:ned 

### shai Jne 

### e?;?e
axe 2,530 g of near equivalent 

### to 

### 6.55 mg 1080 

### or an average of 9.73 mg per feeding and that 

### the othereagle consumed 3,005 g of 

### neaz equivalent 

### to 7.44 mg of 1080 

### oran averace of 6.33 per 

### f2eding. The hawk was detemined to have consumed the equivalent of 3.55 mg 

### of 1C80


### or an average of 0.39 mg 

### per feeding. 

### No discernible

### effects from this consumption of meat containing 1080 were found. Similar 

### tests with red-tailed 

### hawks resulted in

### a finding 

### of no roxic ~ffxts on the hawks and in 

### fact, the hawks gained 

### weight. Dr. Savarie pointed 

### out that 5 rng/kg 1080 adninistered

### to the 

### coyotes was approximately ..I clrnes ;~-ie eszirnateci LDrOO of 3. I6 ~sig/kgana a SLD of 

### 5 m3 1080 would contzin about three SLD~OO 

### doses for 

### a 

### ten kg coyote. 

### He estimated that 

### a coyote punct!jrin2 

### a tzxic ~2: wouii reczive a

### n+ximun oi

### 1C TG 7033 sr 2paraxi,~ateig 5:n L3, I L\J

-,- dosas fsr a 

### :?n '<;



### a SLD cgntaining 5 rng 1030 or by 2 xxic csiiar ~woul?not pres~nx a 

### 24/ 

## - hazard to rapt3rs. 194. 

### Dr. Savarie (finding 192) testified that one 07 the diificulries io determining the priinary and sec3ndary hazards to non-tzrg2r. specles fvcn the us2 of 1080 has been the lack of reliabl? x~hods 3f aersur'ng

-, low levels cf 

### 1680 residues

# 'n 

### xissues of animals susoectzd OT seing poisoned. Problems aith che use 3: c~lorirnezr;~ and Gas chrcnatsgrzpnic (flame ionization det~cior) iesi methods include the rzldt? veiy 1arge sample sizes (50 

### to 100 g) raquired for leternination of 

### iC80 1eve1s
ds low as 3.5 porn. 3r. Savarie indicatad thas :he develocmen; and reiinet: l: 07 more sensiti

### \te methods, 2.3. gai cnrcmzt.zgr~~h;/ xith elecirctrj cd;; :ure detecii

### on and sass spectrcnetry

### , have arlablsd the 1 detection 

### of less than 0.1 pprn ci

### IOSO in one gram saeples. Se asserrel
+3&2JOT-?acc!~rac? analytical methods c~rrently ~vailab12 would faciliLb. sssesiments of tne hzards cf 1C80. Although i)r. Srvarie st212d that current nethods could detect fluorc;citrat?, he ackncwledsed that fluorocicrat2 ~culd 

### not be derect2d in a t2st for 1080 

### res'dues. 195. 

### In other afforts 

### to deternine possible secondary poisoning hazards from 

### the carcasses ofcoyotes poisoned by 1080, 

### MS analyzed 

### 1080 residues



### 241 Coyote meat fed the raptors consisted of skeletal or muscle tissue. 1 

# - -+ 2- Uc^F-^:--l LL-L --^A .-*-: 7 7 , .z =,J 

## -- -2 -,-- -. r;t ""'


# __ , --_j, t.-;- -.a,C' ! -r-37: .u. ,8aL.. 1, 8--4 Us, + ,J./<I A a 

## ,. ia c viscera night 

### we1 1 contain higher 1080 or f1uorocitrate residues.iil rjssues of coyo%ss which died ifi2r SU~CS~~~ZS xxic CS?:~~S.I; l,vas ~2~2mined chat ;he average 

### iC5C :,-nczntrz;;'zn izxusc;e c':<ue of these coyotes was 0.31 ppm. Average 1020 concentra~ion invorni~us 25/ of poisoned coyotes 

### was 0.14 ppm. Ten magpies- l~er-3 confined with skinned carcasses of coyotes that died after puncturing toxic collars wi:h no orher food availabie. A1though four iirds died and 3ne of the four containea 1080 residues, i

### -, I,\ras concluded that thess birds j~arved ~o deaih. The other six birds apoaren-ly snowed no symotoms 

## -3 of 1330 poisoning. ine conclusion ;he birds cila of s~arvazion 'das based in part 

### on the fact the sljnned c~yot2 CZTC~S~~S Orj?d (ip in the heat and ir

### was concluded chat ~he nagpies could nor sat ! T. 3 Ronald 3ogusky, IH.~.,Ph.O., an Assistant Professor in ihe Vepnr313gy Division of the School of Medicine at :he University 

### of Cdliiornia 3s 3avis, and 

### a ~i tness for Cefenders, point24 3u-c chat the -net;bol ic &I effecii of fluoracitrace nirnjc diaoetzs 

### aelh !tiis, rnich is 3 quasi

## - starvation state and asserted that 

### Hr. Coocol1

### y had riot proved his

- contention that the birds died of starvation. In further tests, a coyot2 Idas given a fiassive overdose of 1,280 (300 ma ar the conrents of 

### a toxic collar)

### , an LDIO~ being aoproximately 1.8 ng. This c3yote
was dissected soon after death and 

### the soft tissues fed 

### to one group ofmagpies for seven days and another group of magpies for tl,vo days. 

### Even though 

### the coyote tissue contained iubstantialiy higher 

### IOSO residues than were found in any coyote killed by puncturing a toxic collar, no evidence of evidence of intoxiiication was observed. it

wan ~uncluaea ilia, iiliporen~ia i ru, seciodary ,ui biin;og 91- II~I~-L~~-~EC

25/ 4n LD50 for a magpie is in the range of 0.6 mg/k to 1.3mg/k. 

## -died aftsr T~edjng 

### on kangarso razz po?son?d by 1G80 r~szdas a rodenticide in Califzrnia and chat c~~yotzs died aft2r fseding 

### zn ground squirrels poisoned by oats creacsd with 1080 in Montana. 196. 

### The citricacid or Krebs cycle is the final riechanism for converticg fodd into onergy in plants and animals. Sodium fIuoroac?tate, kvheq 

## - ingested, is rne-canalized into fluorocitrax, ,rnich innibi

### ts activi:I/

-, 

### of 

### me 2nz;/ne aconitase and depr'ves cei1s of enerzy. 1nis znzyne inhibition results inthe blocking of the l(r?bs cycle, ;uhich secanbariiy blocks glucose inetabolisin, 

### a 1,esserenergy producing process. 3lockage of cnese orocesszs caus2s che energy supply to be r:ducxi co the ?oint where cs1lu;ar pemeabiiity barriers are destroyed, resulting inloss of function and iinaiiy c~llular deach. 3ecaus2 of chis cell destroyin?

-, capabiiizy, fluorcacet,at2 is ref5rred 

### to as a czllular poison. Ine breakdown in intrac~llular proczssss ?ventually results in the appearance of gross organ or organ systzm disorders. Death may result from gradual cardiEC failure or ventricular fibri1lation, or progr~ssive depression of the central nervous system wich eizher card'ac or r~spiratory failure as the terminal event or respiratory arrest following severe convulsions. Death in carnivorous species is thought 

### to be the result of central nervous system disorders. 

### Dr. Savarie (finding 

### 192) cautioned that these were assumed modes of action based


### on tests with rats and had not been proved 

### as to most species. He asserted that there could be other unidentified metabolites which contributed to the toxicity of rnonofluoroacetate. 

### Dr. hlorman Zirmerman

### ,

# - Senior IOX~ cciog-ST 

### =1)r 722 '4ichl;gsn Szazz :;::ic S~;cs:ancz 

### Czn-,rc
1 

# - 7 Csmis;ion and ?I vj

### cnfsi for 12ei?ncers,cickncv4j

### ea;za, ::?z: 5 i 23~7: ;5 07 the aaczzob2 of action by whicn Cor~cuna

### 7380 zx2rrad j;; ~2x1~ 2ffects were noL knohn. k!e assert2d, how~ver, 

### chat its ,~ecfjanj jn
was generally accsp~ed inthe scim~ific csrrnunity 2nd I',ha"L i", );as known that 1080 could.le~hnl ly disrupt basic chemical 

### metabolism in a11 animal

### s inclu0-ing man. 137. Dr. Eagusky (f:nding 195) surgiia! 1y removed kidneys frcm ~arrnal TZTi and perfuszd then [wich

### an oxygenatsd buff2r solution conu.inin5


### serum albumin in an incgbator controlled for t2.'i;per?cur~,, ?h and oxygen. Under thesil canditions

### , kidneys l~ere i~l e 

### to inai

### ntai

### n nomai functions 

### for ac 

### hasi one hour. He added fluoroci

### trax 

### -,a 

### che !~rofusing ~ediurn up to 3 final concenfratj5n of0.1 mM. SurZng 

### che

n course of che experiment kidneys 

### \,vereinszantly frozen afkr LO ninut2s of perfusion prior co adding fluoroci~rate and atzirned intervals therzaf~er.

### Frozen kidneys were axtr2cted and 

### analyzd for tissue metabolitzs. He concluded that fluor3cizracs caused 

### a significant fa11 in kidney cissue adenosine tripnosphate (AT?), a major sourc? of energy, to 43 percent of normal, that kidney function
was reduced to 7/10 of normal and that serious kidney damage had occurred. 

### The purpose of his experiment 

### was todetermine how kidneys produce 

### arranonia rather than to test 

### the 5ffects of fluorocitrate on kidneys. Although Or. Bogusky considered that the concentration of fluarocitrate used 

### was low, itwas approximately seven times the one

-,. - - 

### -tsxic ;all ar. 2rr.3ogbsk;i 

### i~juned :ha: :;2 :gfiverzion 2: fluoroacetece into fl uorcciiratriould be 

### on a one-:o-one >;sj i

## . He defended this conclusion as reasonable asserting That xeamount offluoroacatate not converted notild be trivial even tiloti~n he had no specificdata to support that conclusion. Dr. Zimmerman (finding 196) iestified thai dl1 fluorcacrtazeuould nct be ccnverted r3 iluarocitrate and tnat the quantity canverted :vou;d >12ry.vi~h ;he tissue and the specizs. 

### Dr. Savzrie icated tnat based dccn neraholisii~studies 

### a small percentage 

### oifluoroacetata dould be converred to 

### fluorocitrate. 

### Dr. 3ogusky cansidered thai dama~e to kidneys demonstrz~ed by his experiments iould be the same if i?uorocitrate ar fluoroacstai? uere xken craliy

## . He acknowledged that he had not perzomed those experjments and thdi other 5odiiy functions could impact ingesisd F1uorccitr3te beiore iI reached the kidney. 

### He also acknowledged that the cancen~rations sf fluorocitrate us2d inhis exper'ments on kidneys 3s single organs .~ou'id 

### hzve been lethal to rats. Alrhotigh Dr. ao~usky is clearly 

### an experr 

### on kidneys and their functions, 

### he is not an expert 

### on Compound 1080 or 

### the amount of fluoroacetate converted 

### to fluoracitrate 

### when ingested. 198. 

### Dr. Zirmerman cited a study (Cater, eta1

### ., 1961) with rati treated with f1uoroci:rate, which demonstrated marked kidney damage. 

### He referred ta another test (Sullivan, 1979) where rats intraduced 

### to1L9 co~c2ntra:i~ns of

### ff;e;.sc;'trat? ;n zrinkci:~ :~atzr as 

### :cw as six

.i 

### ??nf3r SZVZZ jay5 S~CWO~ 73r3~:9;c~i~2: 

### izrzse 

### x 13s~2s
, TI; j 5

ait2r 21 days. Rats given sub-lethal dos2s of fluorocirrac? in dr-inking water )lave been shown to srow normally for 

### seven months and then 

### to survix on 

### an intraperitoneai dose of LO rng/kg wnich dcuid normal iyhave been fatal (Peterr, 1971)


### . This indicac3s tha~ a c2rtsin tolersncs for fluor~ci 

### traze 

### mzy be deveiopea. S~uai 2s ii by Atzert also shcw that regeated s1~b-121ha;dss2s of ~onofluoro1Aaq ac2tat2 

### have increased che talerance of scme sgecies, l.g.,9old,. 

### eagles, 

### rats, mica and possibly rbesus nonkeys. Repeatzd sub-iethal dosss of ~onof?uoroacetate indogs, guinea pigs, rabbi^; ana 

### ~al lard ducks, hcwever, accumulatod 

### to lethal levels. 3r. 3ogusky ?oinc?d out 

### ~hae the reason more data ~wasn' t availab13 

### on rlhether fl~oroacs~~:~ accumula~es was because i; ,das 

### so tox'c 2nd chat animals in :he ,di:d would not normally rzcsive xpeated jub-lethal doses.
Issue 

### 6 139. Sodi

### urn rnonofluoroacetate is 

### a xhit2

### , ordor? ess

### , powdery, f1uoroorganic salt similar in apgearanc? 

### to flour, pcwderad sugar 3r baking powder. It isessentially tasteless, having only 

### a mild salty, sour 

### or vinegar taste 

### to individuals. Itis highly soluaole in water, but relatively insoluable in organic solvents such as kerosene, alcohol, acetone, or inanimal and vegetable fats and oi1s. Sodium fluoroacetate 

### is absorbed through the gastrointestinal tract, through 

### open wounds and 

### the pulminary epithelium, the lining coveringair ??ssag?s in the lungs. 1: ij 5o.c re2ci.i~ 3bszr5als'2 ~nrgugh 4

due to rhe scrongth of tho c~rbon-flaorjce kona. cata (finding 181) 

### , however, indicat? that iluoroacecate broaksdown in the soil, being deccm~osed by ertain soil bacteria. Sodium fluoroacetate poisoning is characlzrized by a lazncy period of from one-half hour co clrlo $cur3 aft2r insestfon, ~hich is rel~ted
co tne me~akol ic prqczss2s gescribed akove (fi nding 156)


### . Death is usual1y ldithi

### n 24 hours aiwr ingestion. Dr. Barry ?umack, Associa2 i'rcfesscr of Pediatricr 

### at tne Universixy of Colorado, Uireczor of the Rocky ILlountain Poison Control Center, Denver and a ~~virlness for Jefenders, :2s~ifisdthat he did noE c~nsider sodium f;uoroacetats
robe an acc!irnulative poison in the chr~nologic sense. fie indicatob that the laz~ncy geriod in a numan may be 

### as long 3s =ive hours. 

### 2GO. Reported deaths attributable 

### to 

### 1020 have been 

### in connection (~i th i2
use 

### as a rodenticide rather than us2 as 

### a prsdacide. Dr. Rumack (finding 199) contended that this was irrelevant because 

### ICSO was hishly toxic however used. H2 testified that 

### 7080 poisonings wer? difficuit to diacjnos2 and th~t zany goisonings were likzly to go unreported. Evidence in the record 

### is to the effect that individuals handling 

### or exposed to 1080 in connection with precaration of bait stations or taxic collars did not suffer any ill effxtsprovided proper precautions such 

### as wearing protective clothing were taken. For example, 

### Mr. Charles Howard (finding 71) ruptured the reservoir frcm 

### a toxic collar in the 

### process of adjusting or removing 

### a collar.*.

. 

### fr?m a goac, sp; i !I ng ;he j~luCj,:n 

### ,;n :?j5 iafirjs. 

### ,-e " trashed his

with air;. 

### Nr. 2andall ast ti ifei that in

### che caurse of injec:i,~g 

### meat baits with 7C80 solution, the solution 4r?qu2nzIy s?i173d cn his pants and shoes. He suffered 

### na ill effects. 201. 

### Mr. Glenn Oahien, a Gunnison County, Colorado, Deputll Sheriff 

### became ill and began hal1ucina:ing aft2r handling a 9ieco of eat in a piastic 

### %rapperinthe cmrse of inveszisa-;i!~g a 

### ccmolai~t concerning zne poisoning of same dogs. :l!r. 3ahIsn &as 

### hospicaiizec, treatzd and 

### rel~assd. Subsequent 

### xszs r2vealed that ~he 

### xeac contained 

### 7080. A?chougn 'lr. BanJen did not touch other ckan che wrapper in which <he

### meat I~vascontained, ie did not wash his hands for some tin2 aft~r hand1ing the lfvrappercantainSng the me3:. Another 1,vitness, apparently zuff2t-ing an advers? 

### re~ct? on 

### to II Cs~pound 

### 1080,was 

### Ir



### . 3rian %tchel1 

### who j~Tfe~2C1 i3ca-iizsd numcness after oeing bitten in 

### the rhurrb by his dog which was poisoned by carelessly placed 

### 1080 baits intended far 

### the control of

### rats. 

### Mr. 

### Mitcheil 

### was treatgd 

### as an outpatient at

### the Logan County Hospital (Colorado) and sent home. 

### Ms. Car~y Hopkins, 

### the owner of 

### the dogs involved in 

### the incident investigated by [Ir. Dahlen, wss hospitalized suffering from what Dr. Rumack described as clzsiic symptoms of 1080 poisoning. Classic synptorns of 1080 poisoning include nausea, vomiting, diarrhea and hy7eractivity. Ms. Hopkins a?parently 

### became ill after washing blankets upon which

: ner aogs hao ror;~l cea. ~ii;locign 

### dr. humic~ ~2sci r~ea 

### enat survivars of

### - ,- apparent 3dvers2 27~3~:~. 3r. ,?"nack was unabl 2 c3 ci

### t? ar,y 1nscancss of patienzs recovering from 1380 poisoning who suffered pemanen-c damage. 202. Relatsd to'both environmental and human safety is the matter cf


### -. possible rnisusz o? Ccmpound 1080. ine 1972 order citd 'nstanc2's 

### of rnisuse of toxicants and inaicatsd chat itwas aeprooriat~ 23 consider "comonly rxagnizod prac~icz" and tha~ she iik2lihool of 25/ 

### - label dir=lctionsbei-ng fgllowed may efTect their aiequacy. ii. wi11 be rzcalled thar Hr. Randal? testified that iE das no; possible

I I 

### to nonitor 

### orcontrol the apolicatfon of strychnine ~ro~-baits. 72 indica~zd tha: i? 

### t,-.= 5aits werg coverea, they couid nor 

### subs?cuen:ly be found. He also rfisrred ro 

### the glac2rnent 

### in the fa11 of 1969 cf 51 I

8 r bait stacions

### , some of !+mi ch were on Federal Gover'nmenr prcperzy

### , \,vnicr; had noc been approved by 

### eicher the Forest Service or the 3ureau of Land Nanagernent or for location by DWS. ile ~tatyzd That the82 baits
were placed because of pressure from sheepmen and an overzealous suqervisor in the area. An Gctaber 1969 DWS memorandum, of which

26/ It is not2d that one of the decisions relied upon for 

### the proposition 

### that comonly recognized practics may affect the adequacy of labelling directions (In Re Stearns, 2 ERC 1364 (1970) was set aside 

### on appeal 

### , sub nom Stearns Electric Paste Company 

### v. EPA, 4 E4C 1164, 461 F. 2d 293 (7th Cir., 1972).133



### . , 

### r. Randall .as 

### cre of 2 rzc:2;.n;j, fr;kica:sd :nit iasz.1 ;r, 1 quantity 9f i8C ilS2.' rrc <he

### iunter ;f 3d;:i ~id~ed, 3di~i .ver? bei

### rg ov2r:rea:od, rhers iias pacr rxard keepiog or :has ad;us;;e;er;ii


### were not being made for breaka~e and spillage. 203. Although Nyoming guidelines 

### for the 

### use of 

### 1080 baic scztions dcring the 1975-77 bajting progrm called 

### far 

### a,n average of one station per township, maps of placemenis in the record indicate cnac acre ihan
one sta~ion was ?laced in several 

### towns hi?^ in ir least C~rn~Seil County. 

### kr. Cros5y explained thdz Tore ihzn 

### sne xiiwas ?ermii;bi, if ther~ kers barrisrs juch 

### as a highway or 1 ncuntain range that would separ2ce csyoze populations. In any 2venT, itis 

### ;lear thax baits 

### were not placed in 

### every tohnship and considering the ia~al number oicawnsilips, the averasp 07 ar.e per iownshio was nos excseded. :4r. Croshy also referred 

### to unauthorized novjng aihi;: and t3 

### iae fact chat in certain insiaccas ranchers 

### were allcwec to sescrcy rhe remains aibait stations where because gideaiher and sther factors authorizsd personnel wew 

### not available to do so. 3uring tne Xer nexico 

### tests with the toxic collar under an EUP, 

### an employee 3: one 

### rancner
was suspected of removing the toxic solution from 

### three callars and of storing the solution in 

### an unlahelled contaicer. 

### The collars and the solution 

### were confiscated and the particular rancher 

### was not allowed 

### to participate further in the program. Although similar incidents cannot 

### be ruled out, 

### the collzrs in chis instance 

### were furnished free of 

### charge to participating ranchers by 

### the New ;Yexico

# .? 1 SL &~ar;~ent oG 1,g~icy;:dr~ 3::d it i: 8inliiai;/ :nz: given 5,~ 515.30 8 cast o? cne co;lars ixc.y r3fic::er~ ,/~uIG SUTZ!~ZS~ cs;iars fz~t 

### :;:e Zurpss of cotaining i

### 680. Xr. i4cSride 1i kenzd such a pr3~~i c2 co 2uy'ng 27/ 

### - 2 pickup in orcer to obtain 2 tank ofgasoline. in sum, whill itis clear that the extrsne toxicity of Compound 1086 requires car-eiul monitoring if itis to be 

### used inany fom, the violations ~f 

### Qiz resrrictions shown by this rzcord ar=not a safficient jasis :o deny i

### ts registrati

### on for the uses aurfioriz2d kroi

### n

### . 204. Efforts to deveiop an zntidote for sodium fluorgac2cate poisoning have been unsuccessful to date and troatiient Ss symptomatic, neaning that tnerg is 

### no specific Yreatzent. A three-year old girl (She? ley i400dward) Idas ,hos?itaiized in a comatose condixion 3f t2r Seing found with 

### a mouthf~liof oats wnich kad ;eon scaked in an iinknown a~ount of jodium fluoroacetat~. She xas trcarod ,di~ft e-~hyl a1coho1

### , sodium ace~ate 2nd ac~tamide. She revived after 50 hours and appeared compiet2ly norm1 after 72hours. 

### Dr. Rurnack, however, insistsd that che treatments had nothing 

### to do with her ~PCOVE!~~, the child having r~ceived 

### a sub-iethai dose and that the significance of hospizalization ,das insupportive care, i.g., rnaintenznce of bodily functions. Ee tescffiea tnat if the treatments were effective, she would have revived more quickly. 

### Dr. 8ogusky was of the opinion that she had received a sub-lethal dose, butnevertheless stat2d that she would have died without the treatments.



### 27/ It

### is noted, however, that South Dakota's application for the use of1080 in the toxic collar contemplates that conti-01 of retrieved collars will remain with ADC personnel and itis not clear that itis :-L--A-A --I 1--- LA --1.4 +* ,,.-,..-LA*,- IIIi.eliueu LII~ LUII~I~ uc JUIU LU ICLILLIICI~.

### -.- ccn~roi 

### , ';?izncers 

### nave shown 

### a :: ,Jof 3 dog ~yl nc 3-:~2r >eing adminiscered scdi

### urn f7uoroacs~a~z. 

### 0f cznc2rn her? is ,he 3ss?rri

### on that an animal administered 1080 is in agony. This would seen co depend 

### on whether the animal is cmscious. While this question cannot be answercd with cert3inty from evidmc: in the record, 

### Dr. gurnack, describing th? smptcms of lGSO poisoning, szatad rSa1 pati2nz; oitan complain 

### of 

### a tart, sour tasc2 in heir 

### xou~ns. He ass2rt2d cnat :Re unpleasan-c :=st2 ivas soon iol

### lowed by 

### nausea zndisr vcmi~i ng

### , ;;ngl ; ng sensations in che nose, spreading 

### to the 

### ams and legs and facia; numbness. Sti11 1

### axr, in morg serious ~oi sonings , the pazi

### znt suff~r-s soasinodic 

### muscle ccnt~actions followed 3y generalized seizurs. 

### Dr. 2urnack explained 

### chac the most serious 

### 1080 sympxomz prjrnari1y involve the c~ncral nervous systmand t~e cardiovascular 

### systsm and that aft27 the numbness, tingling, lccntractions and seiz~res refzrrld 

### to above, pazients may also suffer from agitacicn foliowed by de?rsssed consciousness and eventilally ccma and delth. It i: the hyi;2r3cti1licy, muscle contractions and seizures 

### that give 

### the vi2vter 

### the impression thar an animal dying from 1080 is in asony. In this ccnnection, the only apparent mention of pain in 

### the hospital record of Shelley Voodward (finding 204) is,dhen she began 

### to recover after 53 hours. in 

### any event, animals caught intraps and snares and wounded, but not killed, after being 

### shot, are also likely 

### to be inagony.,, . . ,. 

## - ,- 226. ,2,: :hcc;gn !,(ycmi ni; has app; izd =;r c~;? rcci Y s;.ra<: on ST, mucnpszfi~ ;:,?' in 

### a snear posz fomulazicn, <he only ~itnzss t3 ttsciiy resarding such 

### use was 

### Hr. Roberz 3urgee (fi nding 125)



### . The a~pl icati

### on envisages 

### a formul~aryiunof 3.50 percent sodilim rr,oncfluoroaceta~s, 95.50 percent Rhodamine 3 dye and 

### 4.0percent 

### >water. 3lr. 3ur5ee ' Cescribed a smear ?ast 2s a 4 x 

### 4 post into ~,vhich holes werg dri? led
or whicn was scored with 

### an 

### axe inorder to 

### hold scenr nat2ridl acd which 

### was placd in 

### the c2nter of an approxinat~ly 2:-squar2 fcot ~nclosure. He explained that five barbed t,viresIdere uszd for enclosing the post ifthe post was used 

### on sheep range and four ifthe 8;ost *as


### on cattle range. The52 wir3s %er2for the pur?ose o7 keeqing iivesmck away from the oost 3rd ~ould 

### not prevent 2nrr-y by jogs, ima;l ~a,mals ar,d birds. The fonulazion used was mo ouncgs of 

### 1380 3 3 221

### :on of scsnt naterial. 

### Mr. 3urgee r2ferr~d to the sca~ qaterial us& as Y-W without filrther explanaiion. ;-le indicatzd that there was lanolin in the formulation, that itreadily stuck zo ~he posz 

### and :hat on2 ~allon would be sufficient to treac a; 12ast three posxs. Smear 

### 7~~x8 would be placed near driw stations (debd 1ivestock)

### , tho intenz kingthat coyotes would be attracted 

### to the post by the scent material and in \ the course of licking itwould receive a lethal dose of 1080. lu';,oniingls application is silent 

### as to the scent or attractant 

### to be used and the adhesive 

### toenable the formulation to stick 

### to the post.and cold-weazner xonths. Se indjcato? :gat Torn s3uid be ~s?d depending 

### on predation and the nunber of sheep. Given ;he corrsn; ios of horses, which he referred 

### to as "tankers" and )/nich he used ai ICE0 bait5 prior 

### to 1972, and the fact that the rancher usually i~rnished rhe posts and ri

### re, 

### #r. 3urgee iestified chat iiiiear posts were chedper than bait starions. dlzhough his experience :virb smear 

### pcs:s Has li.nited to three cons:rr;cted for experimental pur7oses in the ain~er of 7G56-57, Nr. Burgee tesiified chat chey ere eifxtive, asser:~ 

### ng :he: rte had wailed and idenrified by green aye coyores that 

### were 

### tillsd 5y :ne
smear pos-s. %e

### stated :ha: ne had ?ot found any non-tar;ec 3nina:i

--. neir smear posts because ihere *as 1e ir no non-'.zrgec :,ra:Tic during cbe win;-?re-. 

### -

## 7 

# 35; TO CONTROL STOCK-KILLING COYOTES 

## SHEEP OR GOATS 

### IN THIS 

### AREA ARE 

### WEARING NECK 

### COLiARS 

### THAT CObITAIN A 

### POISON, COMFOUNO 

### 1080 (Sodium

### Fluoroacetaie) 

# DO

# NOTTOUCHCOLLAREDLIVESTOCK, COLLARS,

# ORDEADAN1,MALS. DO

# NOT

# R.EI,EASE I 

# LIVESTOCK i

4 

## EL VENENO, COMPUESTO 1080,

. J .211j ) 

### - J 3 > I 

### EST~ 

### EN UN COLLAR 

### T~XICO EN LAS 

### OVEJAS 

## 0 CABRAS.QGE )-- ,- 

### ESTANATADAS 

# NOTOQUELOS

# ANIMALES,LOS 

# MUERTOS. NO

# SUELTEA l!.w.4S OVEJAS 

# 0CABRAS,,0 -5 i-i .n 5 

### 5 5.

in -w 0 3 rt U1 0 0 0 ---r -i> n a ID 0-50 lil 13 -I 3 -'. c-t hcl- 2. 2.

### -* 0 x < fi < J --'- CDO 3m m

# - Ln< Cln LL --hm act I ad rI ill -0C-t 

### --'.a o ro ,-t 0-5 cto .a m 3 P, a-s i~m cn

-0 3 ol l-i D. -5 

# - In0

I- 0 -2- A 2. 13 

## 2 aas. olo 3 a-5 '-+mnJ 33 rl I0 (U21C-i er, n--I artm 

### . o 1L 0 d -h9. tihere c21iars a;-E in US?, ?~CR lo~ical pojrt ofaccess ;;all 32 cons;.ic~cuslj/pcsred :v.i:h a ~i; inpal (English/S;anl sh) ;.iarninq ;:n no^ Iesj 

### cnan 3" x 19" insizs. 

### Sich sicjns snall be 

### inspecc?~ weekly to insurs chei

### r csnxinued 

### presenco and Iegihi1ity

### , and :ri 11 be removed when collars ore 

### rmoved. 10. 

### Each collar in

### use shall be inspected by the applicator at least once 

### a week 

### to insure that itis properly positioned and unbrok3n. 11. Damaged ar broken coilars shall be 

### removed from the fie1 d and eithe? returned ta the manufacturer f~r repair 

### or disposed ofproperly. 12. Disposal of ?unctured 

### orunserviceabla csllars and contamjnated animaT remains, vegetation and soil shall be acc~rnu1ished by deep burial 

### ata safe location, preferabiy 

### on property owned 

### or managed by 

### the applicator. 13. All persons authorized to 

### possess and use 1080 collars snail store such collars under lock and key in

### a dry place away from fooa, 

### Peed, domestic animals and corrosive chmicals. Collars q~i71 not be jtcred in any structure occupied by humans.7 

## -. %its jhail be pro?arzd, sold 

### or transf2rrzd and usza cniy by Feaer-21 gr Staz3 employees 

### responsibi? i3r 5niiraj ta~age c~nsr31 (,GCC), 

### 'clno ar2 cer-,i-;'i SCI qp'iicztgrf.

(a) Training in ia7~ 

### hand1ing and qiacmenz 3f iri~s, 

# - (j) iraining in disoosa! of bai~r, csn~mina2a :n;~al 

### rornains

### , and 

### ancmi

### nacd 'ie.;ecaci 12n2nd ;c;

### I , 

### - (c) Ins~ructf 

### ons far sr3c;iczl 

### :r?:cx.n: ci1223 ;o; 

### ;onips :n numans and Icnssi7c 

### 2n!zial s

### , (c) L 1,is;ruc~i ons 

### on ~~~3rd kseping

### .



## - s. %its shaii con~ain 

### an inzcti\le :ye una",",rzc=iv? ::, iirds 2nd r?:~,: id2rrtifiaol~ by 

### humans. 

### 6. Saics snai1 je ?lsc?d

### only aft?? ,~eri;'ica~ion 5:~ 

### F?a?ra'I 3r St3~ AOC perrannel tha~ a cgyct? kill or kill s 

### iave cccurrod. 521?c:ion of bai~ 

### jitzs ~cd 313cz'i:snt 

### ;hall 

### be only by qualifi2d ACC 7~rsonnel 

### wno are c~rzi fied z?pli

### cacsrs

### . 

### 7. aai-ts 

### shaii iloc plzcedwithin 300 ieex of 

### ope9 (~ater or near2r than one ni1e to

### occgpied human swellings. 8. Zaitsinaybe plac~d inconjunction

### with araw 

### st3tions (~niaal 

### czrcass2s). However, 

### not more chan ?do 

### baics snal1 be glacd 2: any one 

### draw scation and no 

### Tor? than one 

### of such sttcigns 

### ar ?do 

### baits 

### shall be 

### located on one 

### s2ccion (540 

### acres) of land. 9. Baits 

### shaii be covered with cow cnips, stones, 

### Srzss or hay 3r eirnil?r maioria.1s . !f baits cannot 

### be covered. iaics wi11 

### not be p-iated.

### 12- Nhen baics ar? '~ixzd, each logical ;a;nt 

### 07 Zccssr jhaii 

### ke conspicucus::/ ?os:=!! :gith 3 5i1i 

### npal (English/Spznisn) ~,.rarni ncj si 

### si: not less than 3" x 10" insizo. Signswi71 be 

### inspectzd ~e241;~ 2nd will be rmoved ahen baits 

### are removed 

### or-deter;nined have been cansurried. 2. ;1CC 

### perscnne: ;ha1

### 1 ~SSD lrlri

### ct.5 

### rzcsrcs 

### of :he 'I?liilz?r, 13~3::'377 

### ana 

### aats sai

### ts 'rue72 

### ~Iacsa,A 3212i12c nao jhowirlg :ac.tior; cf Saix placgd snail 

### also be nainrained.

.. , -

## - 14. 

### 2egorts CT 17man

### inj~ries 3nd 

### of ai: anigals 

### zs~n, tar;e~ 2: ,dell 

### as non-sarges, ~i 

## :1 5e ?a62 2y XCC 

### :ersaccel lo ,?$ 

### ar :ne ~pprcpr-i az2 

### Si310 r2zui

### azsry agemy.