UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY WASHINGTON D.C.,20460



### JAN 0 

### 6 2009 OFFICE OF PREVENTION. PESTICIDESAND TOXIC SUBSTANCES



### MEMORANDUM

SUBJECT: Analysis ofthe Role of the M-44 Device and Compound 1080 Livestock Protection Collars in Predator Management @P # 356680 and # 356681) 2 

### FROM: Elizabeth Hill, Economist 

# =- ( 

### [L LO% T 1Wyatt, SeniorEconomist 

# ,41J3& 5 zdl Economic Analysis Branch Biological and Economic Analysis Division (7503P) Angel Chiri, Entomologist Josh Williams, Intern Biological Analysis Branch



### THRU: Timothy Kiely, Chief Economic Analysis Branch

Arnet Jones, Chief Biological Analysis Branch Biological and Economic Analysis Division (7503P)



### TO: Joy Schnackenbeck, Chemical Review Manager Robert McNally, Chief Special Review Branch SpecialReview and Reregistration Division (7508P)



### Product Review Panel Date: November 12,2008TABLE OF CONTENTS:

I


# . BACKGROUND



## ....................................................................................................................... 4

I1


# . LIVESTOCK PRODUCTIONIN THE UNITED STATES



### ........................................ 5

SHEEP PRODUCTION



### ............................................................................................................................. 5 CATTLE AND GOAT PRODUCTION



### ........................................................................................................ 9

I11


# .CHARACTERISTICSOF PREDATION ON LIVESTOCK



### .......................................... 10

IV


# . PREDATOR CONTROL TECHNIQUES



### ......................................................................... 13

1

# .LETHAL PREDATOR CONTROL TECHNIQUES

............................................................................. 15 A



### .POISONS/TOXICANTS



### ............................................................................................................... 15 B



### .COMPOUND 1080 LIVESTOCK PROTECTION COLLAR (LPC)



### ................................................... 16 C



### .M-44 SODIUM CYANIDE DEVICE



### ............................................................................................. 19 D



### .HUNTING



### .................................................................................................................................. 22 E

.DENNING



### .................................................................................................................................. 23 F


### .TRAPPING



### ................................................................................................................................. 24 2

# .NON-LETHAL PREDATOR CONTROL TECHNIQUES



### .................................................................... 25 A


### .GUARDING ANIMALS



### ............................................................................................................... 25 B


### .VIGILANCE (HERDING)



### ............................................................................................................ 28 

### c



### .EXCLUSION (FENCING)



### ............................................................................................................ 29 D



### .DETERRENTS



### ............................................................................................................................ 31 E

.HUSBANDRY MANAGEMENT PRACTICES

.................................................................................. 32 i

. Avoiding high predation areas


### ...................................................................................... 32 ii

. Night penning



### ............................................................................................................... 32

... in



### .Shed lambing



### ................................................................................................................ 32 iv



### . Sanitation (carcassremoval)



### ......................................................................................... 33
v
. Monitoring sheepnumbers (recordkeeping)

................................................................ 33 vi



### .Alteringbreeding times (fall lambing)



### ......................................................................... 33 F



### .EXPERIMENTAL TECHNIQUES



### .................................................................................................. 34

V


# . DISCUSSION AND CONCLUSIONS



### ................................................................................. 34

VI


# .REFERENCES



### ..................................................................................................................... 36TABLES 

### AND FIGURES: TABLE 1: AVERAGE SHEEP INVENTORY. MEAT AND WOOL PRODUCTION. AND TOTAL VALUE. 2003-2007

............................................................................................................................................................. 5 TABLE 2: AVERAGE SHEEP INVENTORY. NUMBER OF OPERATIONS AND AVERAGE HERD SIZE. 2003-2007

............................................................................................................................................................. 7 TABLE 3: SHEEP AND LAMB OPERATIONSBY HERD SIZE

............................................................................. 8 TABLE 4: AVERAGE CATTLE INVENTORY. MEAT AND MILK PRODUCTION. AND TOTAL VALUE. 2003-2007

........................................................................................................................................................... 10 TABLE 5: AVERAGE SHEEP INVENTORY. 2003.2007. AND LOSSES. 2004

................................................... 11 TABLE 6: AVERAGE CATTLE INVENTORY. 2003.2007. AND LOSSES. 2005

................................................ 12

.................. TABLE 7: REVIEW OF LETHAL AND NON-LETHAL METHODSFOR PREDATOR CONTROL 13 TABLE 8: LPC UNITS PUNCTURED/DAMAGED AND SUBSEQUENT COYOTETAKES. FY02 TO FY061 18 TABLE 9: NUMBER OF ANIMALS TAKEN WITH LIVESTOCK PROTECTION COLLARS (LPCS) BY WILDLIFE SERVICES. FY02 TO FY06 (BY SPECIES)

................................................................................. 18

....... TABLE 10: ANNUAL DISTRIBUTION. USE. BY APHIS. & RESULTS OF M-44.2002.2006 AVERAGE 20 TABLE 1 1:M-44s FIRED/DISCHARGEDIN THE FIELD BY APHIS. FY02-FY06

............................................ 21



### .... TABLE 12: NUMBER OF ANIMALS TAKEN WITH M-44 BY APHIS WS. FY02 TO FY06 (BY SPECIES) 22 TABLE 13: PERCENT OF SHEEP OPERATIONS USING GUARD ANIMALS TO PREVENTPREDATOR LOSSES. 2004

.................................................................................................................................................... 26 TABLE 14: PERCENT OF SHEEP OPERATIONSUSING HERDING. FREQUENT CHECKS. AND FENCING



### ..................................................................................................... TO PREVENT PREDATORLOSSES. 2004 29 TABLE 15: PERCENT OF SHEEP OPERATIONSUSING HUSBANDRY MANAGEMENT PRACTICES TO PREVENT PREDATOR LOSSES. 2004

........................................................................................................... 33

FIGURE 1:U.S. LAMB AND MUTTON IMPORTS FROM NEW ZEALAND AND AUSTRALIA. 2003-2007



### ... 6 FIGURE 2: U.S. SHEEPAND LAMB POPULATION. 1920-2008

........................................................................... 9Summary
A coalition of stakeholdergroups has filed a petition requestingthat the EPA cancel the use of M-44 sodium cyanide ejector devices and Compound 1080 (sodium fluoroacetate)Livestock Protection Collars. Although the petition provides numerous grounds for this request, the primary allegation is that they indiscriminately kill nontarget species, including endangered species. These devices are used by livestock producers as a way to control coyotes and wild dogs that prey on sheep and goats. The petition allegesthat these devices are not essential for predator control because adequate alternatives exist. BEAD examined the current usage of M-44 devices and Compound 1080Livestock Protection Collars as well as other lethal and nonlethal predator control methods. Along with differing efficacies,the degreeto which these methods indiscriminately kill nontarget species can vary drastically. It is clearthat all availablemethods play a role in predation management programs and have certain strengths and weaknesses. The componentsof a good predator management program depend on the location and unique predation challenges faced by individual livestock operation. BEAD concludesthat the M-44 devices and the Compound 1080Livestock Protection Collars provide benefits to producers of sheep, goats, and cattle and, in the absence ofthese products, producers would likely incur higher costs andlor more livestockloss. However, BEAD is not able to quantiQ these impacts or estimatethe number of operationsthat might be impacted by the proposed changes in predator management. Given the competitive nature ofthe industry, particularly in sheep production, it is possible that such changes could force individual producers out ofbusiness.



### I. 

### Background
Both the M-44 device and Compound 1080are designed to target and kill predators of sheep and goats; however, only M-44 devices can be used in conjunction with cattle. These predation control methods target canids, especiallycoyotes. Coyotes are attractedto M-44 devices with fetid bait, and when one tries to eat it, the M-44 device ejects a lethal dose of sodium cyanide into its mouth, causing death within two minutes. Compound 1080is used in livestock protection collars (LPC) that has a reservoir containing a 1 % solution of sodium fluoroacetate. Typically, the collar is fitted around the neck of a lamb or kid, although it can be used on an adult sheep or goat. If a coyote attacks at the neck and punctures the LPC, it releases a lethal dose of sodium fluoroacetateinto its mouth.



### In January 2007, a coalition of stakeholder groups filed a petition requestingthat the Agency cancel the use ofboth the M-44 device and the LPC. The petition was based, in part, on risk concerns for nontarget species,most notably those listed as being endangered or threatened. The petition also alleges that these devices are not essential for predator control because adequate alternatives exist (i.e., that there are few benefits). This document examines the merits ofthis allegation with a primary focus on the predation by coyotes on sheep, as this is how the predacides are most commonly used. Findings are also applicableto goat production and, to a lesser extent, cow-calf operations.

This analysis is based primarily on a review of literature, documents available on the internet, comments submittedto the Agency by stockholders,and consultation with state officials and university research and extensionpersonnel. It is qualitative in nature as it is not possible toaccurately quantify the efficacy and cost of predator control measures. Predation problems and predation control areboth highly dependent on localized factors, including field topography and the livestock production system. There may alsobe temporal variabilitywithin and between years having to do with ecosystem fluctuations, such as the availabilityof alternative food for predators and competition from otherpredator species.


### 11. 

### Livestock Production in the United States
Sheep Production Sheep production occurs throughout the entire United States, but is concentrated primarily in the western region of the country. By far, Texas has the largest sheep population of any state in the country, with more than one million head of sheep. California, Wyoming, Colorado, and South Dakota also have a significantnumber of sheep. Together, these five states account for almost half of the sheep population in the United States (NASS, 2008a).

Dozens ofproducts are derived from sheep and sheep by-products; the most important ofthese
are meat (mutton and lamb), wool, and dairy products. Table 1presents statistics for the United States and key states or regions. Wool production and the value of wool vary much more between regions than meat production and value. For example, the West, includingthe High Plains and Mountain states, account for about 30% ofthe nation's sheep compared to 20% in the East. However, the former produces 36% of U.S. wool, by weight, and almost 45% by value, while states in the East produce about 18%of wool by weight and less than 8%by value.

Arizona California Mountain West 

## ' Northern Plains Texas Plains Pacific

1 Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland,Michigan, Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 109 668

East Other United States 1,903 483 1,070

277 272 3,927 42.797

Source: USDA NASS, 2005-2008 PDI; 1,262

148 6,191 181,844 35,859 51,955 20,947 16.506 596 3.400

107,446 7,002 468,282 14,394 3,181 5,210 1,350 1.490 3,596 38.639

6,641

538 36,801 136.70 126.20 166,296

35,231 5 1,692 18,034 15.329 132.60 134.00 104.70 140.30 125.30 96,364

6,49 1 43 1,672 150.40 133.60 132.90

### In 2007, over 200,000 sheep and lambs were slaughtered in the United States. Ofthese, 2% were exported, primarilyto China and Germany (Geisler, 2008a; Geisler, 2008~). The United States imports substantial quantities ofmutton and lamb from Australia and New Zealand, as indciated in Figure 1 (USDA ERS, 2008b; USDA NASS, 2008b). However, lamb and mutton are not particularly popular meats in the United States.With the exception of veal (0.4pounds), lamb and mutton (1.1 pounds) were the least consumed meat per capita in the United States in 2006. Instead, the average American prefers other types of meat, consuming about 87 pounds ofbroiler chicks, 66 pounds ofbeef, 50 pounds ofpork, and 17pounds of turkey, per capita in 2006 (USDA NASS, 2008b). 

### Figure 1: U.S. 

### Lamb and Mutton Imports from New 

### Zealand and Australia, 2003-2007

Year USDA ERS. 2008b Sheep are also raised for wool, and to a lesser extent, milk. Wool production has been steadily declining over the past decade, with 4.7 million head of sheep (35 million pounds of greasy wool) being shorn in 2007, compared to nearly 7.0 million head in 1997 (nearly 56 million pounds of wool). Competitionwith other natural fibers, changes in consumers' tastes and preferences, and the loss ofprice supports for the U.S. wool industry (e.g., the National Wool Act) have all led to the decline in wool production (USDA NASS, 2008). Sheep milk is primarilyused to make cheeses, such as feta and Roquefort. Such practices were only started in the United States in the 1980s,and today only an estimated 75 to 100dairy sheep farms exist nationwide (Geisler, 2008b). Reasons cited for this small number include the relatively high risk nature of this industry, coupled with high start-up and labor costs (Hale and Coffey, 2006). In comparison, dairy goats have proven to be a much more vital industry with an estimated one million head of dairy goats in the United Statesproducing 50 million kg ofmilk annually, whereas a slightly over ten thousand ewes in the United States and Canada produce 2 to 2.5 million kg ofmilk annually (Thomas and Haenlein, 2005).

### In addition to the value ofmeat, wool, and dairy products, sheep production engenders other benefits for the United State's economy. For example, one 2008 study estimated the total economicimpact ofthe sheep industryby using an input-outmodel (Trinidad, 2008). The study quantified the benefits associatedwith transactionswithin the supply chain, incomes received by employees in the industry, expenditures both on the goods and servicesprovided to consumers, and a "ripple effect" from increased expenditures in local communities. Trinidad finds that every $1.OO oflamb produced yielded $1.80 ofbenefits within the industry and $0.84 in additional spendingwithin the local economy. Furthermore, for every 25jobs created in the sheep industry, 10 jobs are created in associated industries, such as feed stores, while six jobs are created as a result ofincreased consumer spendingby sheep industryrelated persons. Sheep operations vary considerablyby the region ofthe country. Operations in Eastern states are typically much smaller, with an average flock size of less than 50 head, while flocks in states in the West average more than 200 head (Table 2). Pasture conditions also influenceproduction arrangements, with arid regions includingArizona, and the Mountain and the Plains states, which generally require more land per sheep than in the East, California, and the Pacificregions.

Table 2: Average Sheep Inventory, Number of Operations and Average Herd Size, 2003- 2007 Number of Ranches

Source: USDA NASS, 2005-2008; 1 Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. 5 Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan,Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin.

While the state and regional averages vary considerably, most sheep operationstend to be small. Approximately 90% of sheep farms in the United Stateshave fewer than 100 head; however, large productions with 1,000+head can be found in areas such as Texas and the Mountain West,
as shown in Table 3 (NASS, 2002).The United States has faced a drastic reduction in sheep operations,with the number of operations dropping fi-om 1 1 2,580 in 1986 to 72,680 in 1997-more than a 35% decrease (Geisler,2008c; NASS 2008e). This decline has slowed in recent years with 70,590 operations in 2007, implying less than a 3% decline since 1997.With this overall decline in the number of operations, the total sheeppopulation in the United Stateshas dwindled.From its peak in 1942 of 56 million head, the sheeppopulation has decreased by more than 78% to 6 million head nationwide in 2008, as seen in Figure 2 (NASS 2008a; Geisler, 2008~). Sheep numbers have continued to decline in the United States,with a decrease of more than 20% in the last decade. A similartrend can be seen in states that have state-limited registrations for the use of M-44s and 1080s, which have had a 29% decrease in their sheeppopulation fiom 1997-2007, and an 8% decline in the number of operations. Although predation has often been viewed as a major cause of livestock loss, the overall decline in the industry can be largely attributed to changes in consumers' tastes and preferences and increased land and hay prices (Berger, 2006).

East 3 Other United States Source: NASS, 2002 

# ' Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri,New York, North Carolina,Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 21,001

5153 44,562 10,3 84 1,278 20,664 2,254 155 5,670 433 23 1,995 58 5 893Figure 2: U.S. Sheep and Lamb Population, 1920-2008
60,000

50.000 

# 1 40,000

30,000

V 

## II 

# 3 20,000
10,000

0 

### 2 \ 

### 2 kc3 

### 2 \ 

# @&86dop'op 

# &Q8& 4 4 

# &&% 

# &@@@

.................... Year
Source: NASS, 2008a

Cattle and GoatProduction Cattle production, like sheep, is conducted throughout the United States. Cattle and sheep production often co-exist and will exploit the same or similar grazing land, particularly in the Western United Stateswhere production systems are characterized by extensive grazing on marginal land.

Cattle production provides significant value in meat and milk. Table 4 presents statistics on the number of cattle and the value ofproduction. Production ofthe two commodities varies significantlyby cattlebreed and by system ofproduction. Milk is the primary commodity in California, the Pacific, and most ofthe East, particularlyMichigan. Generally, the dairy system is much more concentrated than beefproduction and requires significant input of forage and other feed. Beef is more important in the Mountain and Plains states where the production system often relies on extensive grazing and few inputs until the cattle are sold to feed lots where they are fattened for slaughter.Table 4: Average Cattle Inventory, Meat and Milk Production, and Total Value, 2003-2007 S

tate/Region

Arizona California Mountain 

# ' Northern Plains Texas Plains Pacific East



# ' Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 6 Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, and SouthCarolina. Cattle (1000 head) 898 5,360 11,324

5,482 13,940 18.230

Southeast Other United States

Statistics on goat production are limited. The main commodities in goat production are meat, dairy products such as specialty cheeses, and the wool, specificallymohair. 2,506 29.138



### 111. 

### Characteristics of Predation on Livestock Meat
(Ioo0 lb

# :ve
weight 585,944 1,974,627 5,609,614 2,252,776 7,217,146 10.612.379

Source: USDA NASS. 2005-2008 8,398

750 96,026

Predation on Sheep 1,160,870 9.613.790

Sheep and goats in the United States are subject to predation by cougars, wolves, coyotes, dogs, bobcats, lynxes, bears and, to a lesser extent, wolves, foxes, eagles, ravens, and vultures. Sheep are especially vulnerable to predation because aside fromrunning, they have no means of defending themselves. In 2004, approximately 66,400 sheep and 157,800lambs were lost to predators out of an estimated total population of 6.1 million sheep and lambs. This number represents 37.3% of sheep and lamb death losses that year (APHIS WS, 2007). In 2004, predationby coyotes and dogs accounted for 51.7% and 22.7% ofthe sheep and lamb losses, respectively (APHIS WS, 2007). This implies that, in sum, coyote predation accounted for 50,893 sheep and 1 15,911lamb deaths that year. Again, differences arise across regions of the country, with predation losses and losses to coyotes relatively high in the west, especiallyin the Mountain States of Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming, in Texas, and in the Pacific. Losses are relatively low in Arizona, California, and the Eastern United States (Table 5). Among Eastern states, West Virginia stands out as having substantially higher losses to coyotes on average. The high predation in some areas of West Virginia may be due to the state's terrain, which provides natural cover .and

### abetter habitat for coyotes. Milk Production (1,000,000 lb) 3,821 37,796 22,181

1,938 6,521 4.547

2,528,012 162,871 41,7 18,029 7,761 82.758 Total Value ($1000)
1,044,202 6,507,339 8,300,438 2,401,23 1 7,129,004 9.5 19.465

5,225 4,584 177,131 Value per Head



### ($1 1,020 1,165 1,055 1,040

790 865 2,192,214 20.940.878 1,040 950 2,996,787

868,422 61,899,981 785 1,180

930Table 5: Average Sheep Inventory, 2003-2007, and Losses, 2004. 

# I State (1000 head)



# 1 Other 148 20,600 5,500 

## 1 1,900 

## 1 1.3 Sheep 

## I Losses, All 

## / Losses to 

## I Losses to 

## I Loss to 

# I

Arizona California Mountain West 

# ' Northern Plains Texas Plains Pacific East

West Virginia 

# I United States 6,191 600,300 224,200 

## 1 135,600 

## 1 2.2

Source: USDA NASS, 2005-2008;USDA 2005. Causes (head)

1 Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. 

## * Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 109 668 1,903

483 1,070

277 272 1,262 34

Predation is also highly variable within regional areas. Nunley (1995) reports that coyote losses in Texas averaged only 0.4% ofthe sheep population and 1.7% of lambs. However, the distribution of losses is very inconsistentwith 54% of producers experiencingno losses, while 12%ofproducers suffered losses in excess of 10% oftheir herd. Factors that influence the degree ofpredation include field topography, with more rugged terrain enabling coyotes to more easily stalk sheep; large fields; availabilityof other prey; and even individualpredator behavior (Tirnrn and Connolly, 200 1;O'Gara and Rightmire, 1987). Predators (head)

Non-predator losses include disease, weather, and accidents. Thepetitioners allege that these losses are greater than those caused by predators, and that there is littleto no benefit arising from predator control. However, this comparison is flawed as losses due to other causes other than predation are irrelevant to the benefits assessment ofM-44 or LPCs. The impact of canceling M44 and LPCs would be the additional livestock losses andlor the added cost of predator control that producers would face in the context of existing losses for other reasons. 4,000 26,000 162,000 49,000 99,000 37,000 2 1,000 181,700 7.500

Coyote predation on sheep 

### and lambs tends to increase during the spring and summer, throughout the period when coyotes are rearing pups and have a greater need for food. Lambs are especially vulnerable to predationby coyotes during this time because most ofthem are born during this season. Radiotelemetry studies suggestthat most predation on sheep is doneby select groups ofbreeding pairs characterized as territorial "alpha" coyotes (Sacks et al., 1999; Tirnrn and Connolly, 2001). Coyotes also tend to attack their prey at the throat. O'Gara et al. (1 983, cited in Connolly and Burns, 1990) reported that 74% of coyotes attacked the neck or Coyotes

(head) Coyote (% sheep) 2,000 1 1,000 88,500 10,700 57,000

8,600 10,900 30,000

3.300 1,100 7,200 59,000

8,900 29,500

5,200 7,200 15,600

2.100 1.O 1.1 3.1 1.8 2.8 1.9 2.7 1.2 6.3throat when killing sheep, while Nass (1977, cited in Connolly and Burns, 1990)reports that 82% ofkills exhibit neck or throat wounds.

Goat losses are similarto sheep with about 40% of losses in kids and 30% oflosses in adults attributed to predators in 2004 (USDA NASS, 2005). The value of losses to predators amounted to $16 million in 2004.

Predation on Cattle Cattle suffer relatively lower rates of predation than sheep as they are larger and better able to defend themselves. However, given the number of cattle relative to the number of sheep and goats, the absolute number of cattle lost to coyote predation is similarto losses in sheep and of much greater value. See Table 6. Losses of cattle to coyotes are valued at $43.9 million (USDA, 2006).

Table 6: Average Cattle Inventory, 2003-2007, and Losses, 2005. 

# I State Cattle 

# I Losses, All 

# I Losses to 

# 1 (1000 bead) Causes Predators

Plains Pacific Losses to Coyotes

East Southeast



# ' Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. 2 North Dakota and South Dakota. 3 Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 6 Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, and South Carolina. Loss to Coyote

18,230

2.506

Other United States

As indicated in Table 6, cattle losses to coyotes as a percentage of cattle are greatest in the Southeast, an area with very limited sheep production. Beyond that, a similarpattern of losses emerges in cattle as with sheep, with relativelyhigher losses in Texas, in the Pacific, and in the Mountain states. 'Losses diminish in the open plains and in the East. 29,138

8.398 610,000 109.000

Source: USDA NASS, 2005-2008; USDA 2006. 750 96,026 1,442,000 347.000 1 8,900 7.000

33,000 4,05 1,000 45,100 38.700 9,400 2.900

900 190,000 0.05 0.12 22,800 18.800 0.08 0.22
I - - 600 97,000 0.08 0.10

### IV. Predator Control Techniques

The main objective of a predator control program is to reduce the losses that predators impose on livestock. Ifthe cost ofpredator control is less than cost of losing livestockto predators, a predator control program can have a positive impact on a livestock producer's economic wellbeing. Programs typically encompass a range of activities, including avoiding predators, deterring attacks, and removing predators. Predator management is dependent on a variety of factors outlined in Section I11 ofthis document.

Comments submitted to the Agency suggest that many producers rely on a mix of predator management techniques, both lethal and nonlethal, to protect livestock from predation by coyotes and dogs1. Non-lethal methods include the use of guard animals, herding, fencing, deterrents, and husbandry practices. In some cases, predation is unmanageable with the use ofnon-lethal methods, and livestockproducers must depend on lethal control methods. A short summary of both lethal and non-lethal techniquesis provided in Table 7. Common lethal predator control methods include poisons and toxicants,hunting, denning (a predation control strategy that seeks to eliminate entire coyote family units, including pups in dens), and trapping. The use of any combinationofpredator control techniquesis sometimes described in the literature 

### as integrated predator management ("IPM). For instance, in discussing the role of guarding animals, Wilbanks (1995) states that donkeys are 

## "... compatiblewith most traditionalmethods of predator control and can be used in an integrated predator management program." Similarly, according to Franklin and Powell (1994), the best protection to livestockis accomplished through an IPM program that includes both preventive (i.e., nonlethal methods) and selected lethal control methods, since it is likely that no singlemethod is fully effectiveby itself.

Table 7: Review of Lethal and Non-Lethal Methods for Predator Control



## ' These methods are described in detail in Sections IV. 1 and IV. 2.

13 Predator Control Methods "Efficacy" Considerations Comments/Drawbacks

These devices may fail at times. They also require frequent inspections and regular maintenance.

A lamb is lost for every predator that is taken.

This method is time-consuming and may require the servicesof skilledhunters. Aerial hunting can be expensive. Although, technically, these are not lethal tools, all trapped coyotes are quickly killed. Trapping is method that requires a great deal of skill and experience. This method is time-consuming and may require a great deal of tracking and hunting skills. Lethal M-44 device

1080LPCs

Hunting

TrapsISnares

Denning Relatively effective,but not selective,
as it will kill any canid predator attractedto the scent whether it is the offending predator or not. Effective and highly selective in that it kills a predator only after it initiatesan attack on a lamb. Effective but not selective, since the hunter may not necessarily target sheep-killing predators. Relatively effective,but not selective, although selectivenessincreases when the traps or snares are set only at or
near the site of a recent kill. Effective, as long as only dens of offending coyotes are targeted.The lethal predator control methods discussed in this paper are not readily comparable, as each represents a different control tactic. Although these techniques directly (M-44s, LPCs, shooting)
or indirectly (traps and snares)result in the death of offendingcanids, they all have distinctive characteristicsthat would preclude direct efficacy comparisons. M-44s, traps, and snares are all stationary devices that rely to a large extent on the selectionofthe placement site. That is, they
are most effective when placed on or near the site of a previous killing or in the path of a predator. Theproper setting oftraps and snares requires a great deal of skill that only comes from practice and experience. Still, older, experienced coyotes can learn to avoid these devices. These methods require investing time and labor to set the devices and to inspect them on a Nonlethal Guarding animals (dogs, llamas, donkeys)

Herdinglvigilance

Fencing

Deterrents (sound and light-emitting frightening devices)

Avoidance of high predation
areas Night penning

Shed lambing

Sanitation (carrionremoval) Fall lambing

Monitoring Fairly effective for smalleroperations. Effectivenessmay vary with the individual guarding animal. Best used in conjunctionwith other methods, such
as fencing.

Effective when the herders are skilled and alert. Effectiveness is also related to flock size. Effectivewhen properly constructed and maintained. Works best for smaller operationsand when used in conjunctionwith other nonlethal methods. Effective for short periods (weeks to a few months). Work best with smaller operations and when used in conjunction with other nonlethal methods such as fences. Avoiding such areas will likely reduce the risk of predation.
Herding flocks into enclosures each night reduces the risk ofpredation. Worksbest with smalleroperations. Probably very effective in protecting lambs during their first few months of life. The prompt removal of carrion is meant to avoid attracting predators and reduce the risk of predation. Shiftingsheepbreeding to May-June so that lambs are born in fall rather than in spring decreases the high risk of predation that occurs during spring, when coyotes are raising pups. Producers who check sheep numbers fi-equentlyare able to detect losses and take appropriateactions before too many sheep are lost. Dogs need to be raised and imprinted with sheep. Vigilance traits vary from dog to dog. Guarding dogs have a relatively short life span and must be replaced frequently. Llamas and donkeys oftenbecome effective guarding animals, but may not accept guarding or herding dogs. Experienced herders may not be easily found, and their servicesmay be cost-prohibitive or impractical for some producers. Impractical for large operations that extend
over many squaremiles and/or where the terrain is highly irregular. High maintenance cost. Predators eventually get used to these devices and ignore them. The loud soundsproduced by gas cannons and electronic devices after dark may disturbneighbors.

This approach may interfere with the effective utilization of pastures or other livestock practices. Not a practical measure for the larger operations. Because of logistics and labor costs, this practice is more suitable for smaller operations.

This measure may be impractical for the larger operations.

Fall lambing may not be compatible with range conditions and marketing strategies. Also, the natural estrus cycle of ewes must be artificially altered, and this is a costlyprocedure.

This is not always practical, especially for large operations. Complex topography and extensive grazing lands can make it hard to get accurate counts on a regularbasis.regular basis. Outfitting a herder with a fire 

### arm for use against approaching predators can also be considered a stationarymethod, as it would not require the herder to actively hunt predators.

The use of LPCs is relatively unique in comparison to other control tactics. Essentially, a group of lambs wearing LPCs is used as bait. If a coyote attacks one ofthe collared lambs and punctures the LPC, both the coyote and lamb will usually die, since the coyote will kill the lamb before it succumbsto the effects ofthe poison. Although this approach is highly specific to taking confirmed predators rather than nontarget species, there is no assurancethat the lambs outfitted with the collars will be attacked. LPC effectiveness is also difficult to measure, with severalunprotected lambs possibly being killed before one wearing an LPC is attacked.

Ground and aerial hunting, as well as denning, require the active pursuit ofpredatorsby skilled individuals. These activities are generallyused as last resort options when stationary methods have failed to take known predators. Whereas stationary lethal methods can be used for extended periods, hunting tends to be a focused, time-limited activity.

Nonlethal predator management techniques, on the otherhand, aim at decreasing the risk of predation through livestock protection measures. For example, guard animals, fences, and predator deterrent devices can be used singly or in various combinations. Depending on the location, these methods may effectivelydecrease, although not totally, eliminatepredation. Lethal and nonlethal control methods are not necessarily replacementsfor each other, but are rather different tactics that in some situations can be integrated for better results.

A primary uncertainty in this analysisis the difficulty in fully accounting for the costs ofvarious control measures, which include direct and indirect costs. Throughout this analysis, BEAD presents information it obtained about direct costs of predator control techniques, which primarily include material costs. However, even these costs are difficult to interpret and quantify in terms of a typical analysis done to compare pesticides, which are often highly substitutable. The cost oftraps or fencing per mile is not necessarily informativewithout knowing the specifics of a location that determine the necessary number oftraps or the length of fencing. Indirect costs, especially labor, are extremely difficult to quantify as the level of effort required or expended may be a function oflocal conditions, such as terrain and weather, and is also likely to be a function ofthe level ofpredation or threat ofpredation. For these reasons, BEAD can characterize certain situationsbut is unable to draw clear conclusions as to the economic feasibility ofparticularpredator control techniques.

1. Lethal Predator Control Techniques

The only three active ingredients specificallyregistered for coyote control in the United States
are sodium cyanide, sodium fluoroacetate, and sodium nitrate. Sodium cyanideis used in M-44 ejector devices, sodium fluoroacetate is used with LPCs, and cartridges containing sodium nitrate and charcoal are used to produce carbon monoxide inside coyote dens (Fagerstone et al., 2003). Both sodium cyanide and sodium fluoroacetateare restricted-use pesticides registered by theEPA and can only be applied by certified applicators. Sodium nitrate is not a restricted-use pesticide and therefore can be applied by non-certified applicators.

The U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) is the primary applicator of M-44s and LPCs in most states, although states that have cooperative agreements with APHIS often have a high proportion of applicators being certifiedby the state. For example, the Texas Department of Agriculture, which has a cooperativeagreement with APHIS, has certified 1,135 M-44 applicators, while only 172 M-44 applicators in Texas are directly certifiedby APHIS' Wildlife Services (TDA, 2008).

Thepetitioners allege that APHIS fails to assist livestock producers with non-lethal controls and therefore perpetuates the use ofpoisons. However, APHIS wildlifemanagement encompasses a number of alternatives. For example, APHIS research developed the "Electronic Guard," a frightening device that has proven useful in reducing sheep predation by coyotes. The petitioners further allege that the APHIS predator control program is a burden to taxpayers when the decline ofthe sheep industry is not caused by predation (Berger, 2006). While it is clearly the case that market forces are largely responsible for the decline in the sheep industry, predator control makes an important contribution. According to Berger (2006), federal and cooperative fundingon livestock protection is positively and significantlyassociated with greater numbers of sheep. Regression results indicatethat a $1,000 expenditureon predator control leads to an increaseofnearly 70 sheep, on average, with a value of around $9,300, given the estimated value per head shown in Table 1 ($132.90).
b. Compound 1080Livestock Protection Collar (LPC)

The LPC is designed to selectivelytarget and eliminatepredators that initiate an attack on small livestock. A LPC consists oftwo rubber bags, each containing 15ml of a 1 % solution of sodium fluoroacetate. It is attachedto a collar-like strap that is placed around the neck of a lamb or kid so that the bags lay beneath the throat,just behind thejaw (Rollins, 1995). When a coyote attacks a lamb or goat wearing the collar, it will likely tear it and release the toxicant into its mouth, causing its death within a few hours.

Sodium monofluoracetate is only distributedthrough the predacide's soleregistrant, APHIS (EPA, 1995). The LPC is permitted in five states: Montana, New Mexico, South Dakota, Texas, and Wyoming (EPA, 1995). Ofthese, New Mexico and Texas are the only states that actively use Compound 1080. Scattered use can be seen throughout states that do not hold state-limited registrations, such as West Virginia, which must obtain written permission from the U.S. Fish and Wildlife Service prior to application. Californiaand Oregon banned the use of Compound 1080 in 1998 (EPA, 1995;USDA APHIS, 2008b).

The 1995 RED for sodium monofluoroacetate specifiesthat LPCs cannot be used in pastures that are greater than 2,460 acres (4 mi2)unlessrainfall in the area averages less than or equal to 20 inches; then, LPCs can be used in pastures up to 10,000 acres (16 mi2). Additionally, restrictions exist on the number of collars per acre, with a limit of 20 collarsper 100acres, 50 collars per 101 to 640 acres, and 100collarsper 641 to 10,000 acres. The collars must be checked weekly, weather permitting.Studies show that the efficacy of LPCs is highly dependent on (1) if the sheep are kept in a pen or a field and (2) the ability to direct coyotepredation to collared individuals.

### In pen tests, Connolly and Burns (1990) found that coyotes attacked sheep over 75% ofthe time when given the opportunity. Of41 attacks, 36 were to the neck and throat area and resulted in 26 punctures to the collars and 24 coyotes killed. That is, collarswere punctured in 63% of all attacks and in 72% ofneck and throat attacks. Coyotes succeeded in killing 34 lambs. In field tests, 32 attacks
or 48%, ofwhich 64% were neck and throat attacks,resulted in punctured collars. Only three coyotes were confirmed dead, including one found nearly a mile away (Connolly and Burns, 1990). A field study in New Mexico found a 50% puncture rate on collared sheep (Wade and Connolly, 1980, cited in Connolly and Bums, 1990) while a study with goats in Texas reported a puncture rate of 83% (Littauer, 1984cited in Connolly and Burns, 1990). Targetingwas achieved by placing flocks with collared lambs in areas ofrecent predation losses2. Even though the collared lambs amounted to only about 3% ofthe flock, roughly half of the coyote attacks involved collared individuals (Connollyand Burns, 1990). Targeting may be relatively easy, if certain locations aremore conducive for coyotes to hunt. Localized predation may alsobe due to specific coyotes. In the pen tests, four ofthe 24 coyotes killed were involved in multiple attacks, including one coyotethat attacked five lambs before puncturing a collar.

LPCs cost around $25 each (USDA PSD, 2008). This does not account for the costs of maintenance or other labor costs,but it is likely that they are significant since the 1995RED for sodiummonofluoroacetate specifiesthat they must be checked weeklyby certified applicatorsor by persons under their direct supervision (EPA, 1995).Furthermore, for an LPC to be successful,
a sheep or lamb will probably be lost in the attack. With the average sheep or lamb valued at $138/head in 2007, such livestock losses could have severe economic impacts on producers (USDA NASS, 2008e). Although LPCs are recognized for being one ofthe most selective forms of coyote control (i.e.,it targets offending coyotes), limitationsoutlined in the 1995 sodium monofluoroacetateRED on the number of sheep that can be collared within a flock as well as the time and money involved in using them has led to a very small proportion oftotal sheep producers in the registered states actuallyusing them (Table 8).

2 All ranches participating in the tests had incurred at least two lossesto coyotes within the previous week.Punctured1 Coyote Punctured1 Coyote Punctured1 Coyote Punctured1 Coyote Punctured1 Coyote Punctured1 Coyote Damaged takes Damaged takes Damaged takes Damaged takes Damaged takes Damaged takes NM~ 15 2 52 4 18 3 16 2 34 4 27 3 PA - - 3 0.6 0 TX 115 29 74 22 84 27 87 23 55 23 83 24.8 VA 3 1 3 6 2.4 0.2 WV 12 10 13 9 14 14 25 22 20 14 16.8 13.8 Total 145 42 142 35 116 44 134 47 112 41 132 41.8 Source: USDA, 2008b; APHIS WS, 2002-2006. It is likely that the number of coyote takes presented in this table is underestimated. This is because death does not occur instantly, and recovery of the carcass may not be possible. This data is from LPC use reports, while data for other states is from APHIS WS program data reports. Additionally, since only a certain number of sheep in a flock are allowed to wear 

### a collar, a producer cannot know how many sheep will be lost before the offending coyote attacks a sheep that is wearing a LPC. For example, 47 coyotes were taken with LPCs in 2006 (Table 9) (APHIS WS, 2006; USDA, 2008b). With over 80,000 coyotes being taken by Wildlife Services during this year, LPCs only account for 0.06% of all coyote takings (USDA, 2008b).

Table 9: Number ofAnimals Taken with Livestock Protection Collars (LPCs) by Wildlife Services, 

### FY02 to 

### FY06 (by species) LPC TMN', Number PuncturedlDamaged,and Species Take by APHIS WS Program nationwide FiscalYear FY02 FY03 FY04 FY05 FY06 Average WS LPC TMN 44.5 48.1 58 52.4 62.8 52.4 LPCs Damaged 145 142 117 1 34 113 132 # LPCsKMN 3.3 3 2 2.6 1.8 2.6 Target Take Coyote 43 40 47 52 47 47 Nontarget take Bobcat 1 

### - - 0 Feral Dog 

### - - 0 Total All Take 44 40 47 52 47 47 Species per TMN CoyotesKMN 1 0.8 0.8 1 0.7 0.9 NontargetrrMN 0.02 0 0 0 0 0.01 % Nontargets 2.30% 0% 0% 0% 0% 0.80% Comparison of LPC Coyote take with All APHIS WS Take All WS Coyote 86,348 75,714 75,622 72,751 87,476 82,023 LPC Coyotes 43 40 47 52 47 47 % fo WS take 0.05% 0.05% 0.06% 0.07% 0.05% 0.06% Source: USDA, 2008b I Thousand Method Nights. TMN is a standard gauge of efficacy and is calculated as the number of control devices (e.g., trap) placed times the number of nights in which it is operable, divided by 1000.
As mentioned, the LPC is mostly used when predation is already occurring and focuses on eliminating particularly aggressivecoyotes. Therefore, it is unsurprisingthat there is littledemand for the product in areas with relativelylow levels of predation, such as Arizona and much ofthe East (see Table 5). There are notable exceptions, especiallyWest Virginia, to this statement. Losses to coyotes in West Virginia are 6.3% of inventory, an exceptionally high rate. The Appalachiansmay be excellent coyote territory; data show that Virginia and Tennessee also have high lossrates compared to other Eastern states. According to Rollins (1999, a target flock (i.e., one placed in an area to draw coyote attacks) should consist of about one collared lamb to between five and ten adults. Given restrictions on number of LPCs that can be used for a given area, they may be less practical for large producerswho cannot easily separate their flock between pastures and more practical for large producers who can isolate a small group as bait in a predation prone area. The collars are also likely to be useful for producers with small flocks who can collar most oftheir lambs, such as in West Virginia. The toxicant is permitted in a small number of states, of which Texas and New Mexico are the greatest users.

c. M-44 Sodium Cyanide Device

M-44 cyanide capsules are labeled for use in the M-44 ejector deviceto control for coyotes, red fox, grey fox, and wild dogs that are suspected of preying on livestock. The ejector is springactivated and designed to thrust sodium cyanide into the mouth of a coyote as the animal bites and pulls the cyanide capsule holder, which is baited with fetid meat. Sodium cyanide reacts with moisture in the animal's mouth, releasinghydrogen cyanide gas and causing death within two minutes (APHIS, 2002). The device is anchored to the ground and placed in or near areas fi-equented by coyotes.
The M-44 device is widely used to take coyotes and other canids in several states. The sole source for sodium cyanide is the USDA, but Montana, Wyoming, New Mexico, and Kansas Fish and Game Department all hold state-limited FIFRA 

### 8 3 registrations. Area-limited registrations include the Navajo Nation in Arizona, as well as the Texas Department of Agriculture. Capsules can be entrusted to APHIS or any agency working under a cooperativeagreement with a registered user (EPA, 1994).

The U.S. Department ofAgriculture's Pocatello Supply Depot in Idaho is the main supplier of M-44 capsules. During the fiscal years of 2003 to 2007, the averagenumber of M-44 units sold annually in the United Stateswas approximately38,000 to Wildlife Services, while around 3,700 units were sold to State Departments (EPA, 1994;USDA APHIS, 2008). As seen in Tables 10 and 1 1, Texas is by far the largest user ofM-44 devices, firing an average of 13,770 M-44s annually fi-om2002-2006. Oklahoma was the second largest, with an average of 3,228 fired duringthis time period. Overall, an average of 25,264 M-44s were fired or discharged and of these, around 60% (1 7,647) resulted in a take (USDA APHIS, 2008b).The 1994

### RED for sodium cyanide states that no more than 10units per 100 acres ofpastureland
or 12units per square mile of open rangeland are allowed. Like LPCs, M-44 devicesmust be checked every seven days by an APHIS employee or certified applicator.Furthermore, they can only be placed within a seven mile radius of any area where losses of livestock are reasonably expected unless endangered species arewithin the area. 

### Table 10: 

### Annual Distribution,

State Arizona California Colorado Idaho Montana North Dakota Nebraska New Mexico Nevada Oklahoma Oregon Texas Utah Virginia Wyoming United States

M-44s are fairly selective in that they are outfitted with bait that is designed to attract canids. M44s are useful in that once they are set, they retain their lethalitypotential for long periods of time, with little additionalhuman intervention. In a sense, they can be compared to traps and snares, in that these also remain effective for long periods oftime, with littlehuman intervention, other than periodic checking. M-44s are especiallyuseful in the winter months, when the availability ofnatural food for coyotesis limited and traps and snares become less effective as soil freezes. Conversely, M-44s are less effective in the summer, when coyoteshave access to abundant natural food. In additionto weekly checks, M-44s do require someregular maintenance, as these devices are subjectto mechanical malfunctions. Cyanide capsules also tend to absorb moisture and cake over time, becoming ineffective (Green et al., 2005). Source: USDA, 2008b. 1 M-44s distributed are for 2003-2007. 

### Use, by APHIS, & 

### Results of M-44 

### Distributed

# '
70 80 140 260 1,480 1,450 1,700 2,860

220 5,730

700 19,330

1,850 1,520 2,630 41,890 M-44,2002-2006 

### average. M-44 

### Fired 

## - 29 59 54 183 798 837 1,656 1,558 9 1 3,228

230 13,770 

### 674 876 668 25,264

### Table 11: 

### M-44s firedldischargedin the field by APHIS, FY02-NO6 M-44 FiredlDischargedby the WS Program nationwide' State FY02 FY03 FY04 FY05 FY06 Average 

### AZ 109 0 28 0 6 29 CA 72 70 54 50 48 59 ID 288 187 173 114 152 183 MT 1,169 802 667 672 682 798 NE 2,407 2,158 1,438 1,316 96 1 1,656 NM 1,780 1,800 1,359 1,348 1,502 1,558 OK 3,722 3,558 3,460 2,799 2,599 3,228 OR 335 224 158 116 317 230 TX 12,651 14,064 13,829 12,603 15,703 13,770 WY 1,202 588 495 543 512 668 Total 27,062 26,089 24,326 22,852 25,993 25,264 Source: USDA. 2008b. 1 The numbers presented will not match the total, as the statespresented are a selectionfrom the total use. For all of the statesthat firedldischarged M-44s, please see USDA (2008b). 2 M-44 was banned in California, but may still be used on tribal lands.

Efficacy data on M-44s is limited and difficultto interpret. Phillips and Blom (1994) found that using different scents, the average pull rate by coyotes on M-44s was 27%, that is, 58 pulls out of 2 15 coyote visits. Certain attractantsresulted in pull rates as high as 36%. The study was conducted during the summer months when use ofM-44 is often discontinued due to low pull rates. 

### In another study, 86% of sheep producers sampled in Oregon found that taking coyotes with M-44s provided at least some relief from predation. Coyote distribution also appears to play a large role in the efficacy of M-44s, with 41% of coyote takings occurring on 10% of ranches (Nass, 1980).

Some alternativesto M-44s have been noted for being more effective. Guthrey and Beasom (1978) found that in terms of capturelpull rates, leghold traps were most effective, followed by cable snares and M-44s3. This study also noted that although M-44s are more effective in the short 

### runin terms of capturelpullrates, steel traps have a higher catch-per-unitratio. Disadvantages 

### ofM-44 Devices There are several drawbacksto the use of M-44 devices. First, M-44 devices can sometimes malfunction or even discharge in the absence ofpredators, which can lead to accidental takes. Second, the bait may attract and be activated by nontarget carnivores, such as domesticdogs, foxes, or wolves. Non-canids have alsobeen found to pull M-44s. One study on attractants found that 8.6% of cattlevisiting a M-44 pulled it, although there was no active ingredient in the devices for the study (Phillips and Blom, 1994). The authors suggest that herbivores may have been attractedto saltsin the attractantsor merely to the top ofthe device emerging from the ground as no effort was made to make them less accessibleto non-predators. However, M-44s

Pull and capture rates are typically calculated by dividing the number of pulls by the number of M-44 nights, where an M-44 night is the number of M-44~ placed times the number of nights in which the M-44 is operable (Guthrey and Beasom, 1978).placed by Wildlife Services are relatively selective overall, with 90% of animals taken by them being coyotes and over 95% oftakes consisting of target canids, as seen in Table 12.

Table 12: Number of animals taken with 

### M-44 by APHIS WS, FY02 to FY06 (by species) 

# I Species FY02 FY03 FY04 FY05 FY06 Average % of Total 

### ] Target take Coyote 14,832 13,046 11,586 11.667 12.596 12.745 89.67% ~ed Fox 539 400 330 287 320 375 2.64% Gray Fox 276 353 1 84 185 376 275 1.93% Feral Dog 45 34 35 30 49 39 0.27% Subtotal 15,692 13,833 12,135 12,169 13,341 13,434 94.51% NontargetTake Raccoon 318 331 29 1 218 199 271 1.91% Gray Fox 102 156 93 116 87 111 0.78% Striped Skunk 110 167 113 59 77 105 0.74% Opossum 82 83 96 64 113 88 0.62% Red Fox 91 55 69 71 76 72 0.51% Feral Dog 76 68 83 60 63 70 0.49% Kit Fox 25 27 29 25 24 26 0.18% Swift Fox 7 16 19 8 2 1 14 0.10% Feral Hog 5 7 4 7 9 6.40 0.05% Bobcat 4 1 5 15 1 5.20 0.04% Common Raven 1 1 7 1 2 2.40 0.02% Black Bear 3 1 0 4 2 2.00 0.01% Ringtail 0 4 1 2 1 1.60 0.01% Badger 0 4 3 0 0 1.40 0.01% American Crow 0 0 0 4 1 1.OO 0.01 % Gray wolf 2 1 0 0 1 0.80 0.01% Javelina 0 2 0 2 0 0.80 0.01% Woodchuck 1 0 1 0 0 0.40 ~0.01% Bald Eagle 0 1 0 1 0 0.40 ~0.01% Feral cat 1 0 0 0 0 0.20 ~0.01% Chihuahuan raven 0 0 0 1 0 0.20 ~0.01% Subtotal 828 925 81 4 658 677 780 5.49% 

## / Total 16,520 14,758 12,949 12,827 14,018 14,214 100.00% 

## 1 Source: USDA, 2008b

d Hunting Unless prohibited by state laws, both ground and aerial hunting are common methods used to take coyotes. For ground hunting, two common ways for locating coyotes areby aircraft or with scent tracking dogs. Aircraft are commonlyused to locatepredator dens, while scent tracking dogs can be used to track predators andlortheir dens. Aerial hunting, whether done in a fixedwing aircraft or by helicopter, can be hazardous and requires a great deal of skill and must be doneby professionals. Despite these risks, it is by far the most popular predator control method. 

### In 1994, for instance, the Texas Animal Damage Control Servicereported owning two fixedwing aircrafts and one helicopter for coyote control purposes. Although in most states the coyote is an unprotected species and can be hunted throughout the year, hunting may not be suitable or even legal in all situations. For instance, safety concerns may preclude the discharge of fire arms near human habitationsor where people could bepresent. Shootingmay alsobe prohibited by local laws or target predators may move into a neighbor's property and out ofthe hunter's reach. Aerial hunting is only permitted in some states and, although costly, it is generally a cost-effectivepredator control method. Aerial hunting does require special skills for both pilot and shooter. Shootingfrom fixed-wingaircraft works best in open areas with littleplant cover, whereas helicopters are more suitable for hunting
overrugged terrain and areas that support dense vegetation (Green et al.,2005). Although shooting invariably results in the death of one or more coyotes, this approach does not readily discriminate between sheep predators and nonpredators.

A 1999 studyby Wagner and Conover found that the benefits of aerial hunting outweighed the costs. The average cost of aerial hunting in Utah, including helicopter rental, pilot and Wildlife Service (WS) hunter wages, ammunition and incidentals, was estimated to be $425/hour. On average, it took 2.1 hours to cover a field, indicatingthat the total cost of aerial hunting was $893 per field. This translates into a cost of $185/coyote, with an average of 2.3 coyotes being removed per hour. This is inexpensive in comparison to other correctivecontrol predation methods, which on average cost nearly $805/coyote. The benefits come from two sources. First, lamb predation was reduced by nearly 18 lambs compared to areas where no aerial hunting occurred. With the average price for a lamb in Utah being nearly $76, this results in overall savings of around $1,328 from avoided lamb predation. Second, if this predation were to occur, it would require about 20 hours of correctivecontrol predation management (that is, using lethal methods, such as M-44s, snares, and traps to reduce furtherpredation), which costs about $537. Therefore,the total benefits of aerial hunting are calculated by the authorsto be $1,865 ($537+$1,328), which outweigh the costs ($893) at a 2:l ratio. BEAD notes, however, that there is some double counting ofbenefits in this study as the expenditureon alternativepredator control would presumably result in a reduction in lambs lost.

e. Denning Coyotes mate during the winter and their pups are born in the spring. The young usually stay with their parents through mid-fall before dispersing and developing territories oftheir own. A technique known as "denning" is a predation control strategy that employs firearms, sodium nitrate cartridges for gassing dens, and snaresto eliminate entire coyote familyunits. This techniqueis time-consuming, requires a great deal oftracking and stalking skills, and can be employed to remove only confirmed livestockpredators. Denning involves tracking offending coyotes back to their dens, which are often difficultto locate. Denningmay entail killing both the parents and the pups, which results in a 98.2% decrease in predation incidents and a 98.9% decline in the number of sheepkilled (Till and Knowlton, 1983). Alternatively, only removing the pups results in an 87.7% decrease in predation incidents and 

### a 91.6% decline in the number of sheep killed. This difference is likely due to the parents continuingto prey on sheep for their own sustenance, but not for their pups (Till and Knowlton, 1983). Denning is practiced from about April 15to July 1 and may be more cost-effective in comparison to methods that are implemented year round, such as penning. In 1980,the average USDA salaryfor a worker in Wyoming was $1020 per month, plus $650 in monthly expenses($2,681 and $1,709 in 2008 dollars,respectively). Denning usually takes place for two consecutiveyears. Ifthis were the case, it would imply that expenseswould total $8,350 ($21,952 in 2008 dollars) for each worker. If each worker were to locate, on average, 40 dens over the two year period, the average cost for removing each den would be $209 ($549 in 2008 dollars). Given these assumptions, it would only take five days of denning for the benefits to exceed the costs from coyote extermination (Till and Knowlton, 1983). It should be noted that the success rate and the benefits of denningmay vary considerablygiven the difficulties of tracking coyotesto their den. The costs may also be understated as there may be opportunity costs of assigning workers to denning rather than other activities and it is difficult, therefore, to make comparisonsof cost-effectivenesswith other control methods.


### J: Trapping Traps and snares are used to take large numbers of coyotes each year. While trapping alone is not lethal, successful trapping always leads to the death of captured coyotes, usually by shooting it in the head with 

### a .22 caliber 

### gun. Steel-jawed traps and snares are commonly used to capture coyotes inhabiting areas where sheep graze. Traps and snares are often placed near kills along paths that coyotes are known to follow as they approach pens or pastures for livestock. The use oftraps and snares requires a great deal of skill and expertiserelated to coyotebehavior, as well
as an intimateknowledge ofthe grounds to be protected. Coyotes learn quickly, and traps that
are not set correctlyor that arepoorly located will actuallyteach coyoteshow to avoid them. Although coyote lures and scents are commercially available and are often used to attract coyotes, traps and snares arenon-specific and will also serveto capture domestic dogs and other non-target mammals, including small livestock. Guthrey and Beason (1978) found neck snaresto be ten times more selectivethan traps in terms of capturing target species. Studies differ in their reports ofthe number of coyotes that are caughtusing snares, with 20.3 coyotes/1,000 trap nights being caught in Zavala, Texas, versus 5.4 coyotes/1,000 trap nights in Canada. This variation is likely a function of coyote density, temperature, and weather conditions (Guthrey and Beasom, 1978; Pruss et al., 2002). Just as efficacy can vary accordingto local conditions, costs can vary accordingto usage. Traps and snares may be relatively inexpensive; however, the time involved is likely the more critical component. The level of effort expended can range widely. Traps and snares can be set and checked frequently or only at one's own convenience. Sincetraps and snares can be triggered by animals other than coyotes, more frequent checks can increase the likelihood of successfully removing a problem animal and decrease the likelihood oftaking a non-target animal. Diazepam is a tranquilizer that has been used to prevent injury to carnivorescaught in traps. If diazepam tabs areused on a modified neck snare, it decreases the injuries and stress that captured animals incur. This is a valuable trait for a predator removal method to have, since it implies there will be a low kill rate on non-target animals (e.g., grey wolves). Pruss et al. (2002) found that 5.5% of captures in neck snares were nontarget species, which is somewhat higher than that for M-44s, which averages about 4.7% (USDA, 2008b). The use of diazepam reduced mortality of coyotes trapped with neck snaresto less than 2%, suggesting a similarreduction inthe mortality ofnon-target species. However, snareshad to be checked every 12-24 hours, which significantly increases the labor and management cost or use.
Like neck snares, steel traps can be quite useful in removing coyotes while ensuring the well being of nontarget animals if used in conjunction with a tranquilizer. Diazepam tabs are the first tranquilizer of choice, however obtaining this in bulk has historically been difficult. This led to the use ofpropiopromazineHCI and clordiazepoxidemixtures. By using a tranquilizer, 7 1%of trapped coyotes sustained little or no foot damage, which is significantly less than the 43% that
are hurt when no traquilizers are used. In 1980,the price ofpropiopromazinetabs was 20 cents (53 cents in 2008 dollars) (Linhart et al., 1981cited in Connoly, 1981). For the tranquilizerto effectively reduce non-target kills, however, traps must be checked frequently, which can significantly increase costs. Traps and Snares vs. M-44s Studies vary in terms of whether or not steel traps and neck snares are more effectivethan M44s. 

### In Texas, Guthrey and Beasom (1978) found that steel traps aremore effectiveover time on a catch-per-unit basis than M-44s; however, Beasom (1974) found that M-44s were more effective4. This variance may be a function oftime, with Beasom's (1 974) studywas conducted
over a 7 month period, while Guthrey and Beasom's (1978) study was only half that duration. As noted by Guthrey and Beasom (1978), this temporal deviationmay be related to predator removal persistently happening in the same area. It may alsobe related to the fact that M-44s are more efficient at catching coyotesthan any other species, while steel traps are indiscriminateand catch more non-target species, thus reducing the chances that a coyote is caught in the first place (Beasom, 1974). Regardingneck snares, Guthrey and Beasom (1978) found that they likely are less effective than steel traps, but more effectivethan M-44s. However, since neck snares are easy to set up and operate, they can be set out at higher rates and require less labor hours than M44s and steel traps, and can therefore yield higher coyote catch rates than the othertwo alternatives.

2. Non-lethal Predator Control Techniques



### a Guarding Animals Animals commonly used for livestockprotection include llamas, donkeys, and several large dog breeds of European and Asian origin. While guard dogs have been used for sheep protection in Europe and Asia for centuries, this practice was not adopted by ranchers in the United States until the mid 1970s. Guard dogs are selected for their abilityto bond with sheep, especially when pups are raised along with lambs. Unlike herding dogs, guardingdogs arenot trained to respond to voice commands and provideprotection against predators simplyby being with the flock at all times; they alert sheep to the presence of potential predators and actively chase them away if they approach them. Employing guard dogs is incompatiblewith the use of M-44 devices, traps, and snares,unless the dogs are trained to avoid them. Llamas and donkeys are also used as guarding animals as they naturally defend flocks of sheep with which they are placed. Their large size and aggressive behavior may deter coyotes from attackingor even

4 These efficacy measures are based on the capture rate, which is the number of captures/1,000 device days.

25approaching sheep, although coyotes may still be able to attack under the cover of darkness or in rough terrain. Llamas may not be able to distinguishbetween coyotes and domestic dogs and have been known to attack herding dogs (Tirnrn and Connolly, 2001). The same is true of other guard animals. The usefulness of guarding animals is enhanced when used in conjunction with other predator and husbandrymanagement practices.

In 1999,28%of sheepproducers used guard dogs in the United States,while 13%and 9% used guard llamas and donkeys, respectively (NASS, 2000 cited in Andelt, 2004). The number of guard dogs increased to 32% in 2004; however, there was no substantial change in use of guard llamas and donkeys (USDA NASS, 2005). Table 13presents information on the use of guard animals. According to anotherrecent survey, almost one-fifthof 1 1,000Texas ranchers reported having used donkeys as small livestock guard animals (Green et al., 2005). The efficacyofthese methods varies with the type of guard animal used and also with respect to individual animals; some simply lack the drive to defend sheep against coyote attacks. Studies have found that sheep producers in Colorado who did not use guard dogs lost approximately two to six times 

### as many lambs to predators over an eight year period oftime (Andelt and Hopper, 2003 cited in Andelt, 2004). A study in North Dakota reported that sheepproducers experienced a 93% reduction in sheep predation losses after obtaining a guard dog (Pfeifer and Goos, 1982). Guard llamas have also been found to be effective,with the average number of ewes and lambs killed by coyotesreduced from 2 1 % to 7% (Franklin and Powell cited in Andelt, 2004)'.

Table 13: Percent of Sheep Operations Using Guard Animals to Prevent Predator Losses, 2004.

Source: USDA NASS, 2005 1 Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri, New York, North Carolina,Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin.

The use of guard animals is the most common means ofnon-lethal predator control in cattle production, with 38% of cattle operations indicating that they employ guard animals (USDA, 2006).

To date, the efficacy of guard donkeys has not been researched in peer-reviewed publications.

26Cost of GuardAnimals Regarding the costs and benefits ofthese guard animals,pups cost around $150to $500, adults cost $300 to $1,000, and maintenance costs are around $250 annually. The cost of a guard dog is usually dependent on a number of factors, such as breed, age, and temperament (Andelt, 2004b). Thebenefit of guard dogs in terms of avoiding sheep losshas been reported to be between $2,506 and $3,733 annually ($5,225 and $7,783 in 2008 dollars) (Green et al., 1984;Andelt and Hopper, 2000 cited in Andelt, 2004). Guard llamas tend to cost between $450 and $800 ($674 and 1,119 in 2008 dollars), with annual expenses averaging $105 ($157 in 2008 dollars). Again, in terms ofthe reduction in the number oflivestock lost to predation, the annual benefit of a guard llama has been estimated to be $1,253 ($1,878 in 2008 dollars) (Franklin and Powell, 1993 cited in Andelt, 2004). Guard donkeys cost between $144 and $236 ($252 and $314 in 2008 dollars), with annual expenses averaging $66 ($1 15 in 2008 dollars) (Franklin and Powell, 1993 cited in Walton and Field, 1989; Bergrnan et al., 1998, cited in Walton and Field, 1989).

The age of guard animalsmust alsobe considered when assessing the benefits they can provide. Dogs live 10- 12 years, and can be ready to guard livestock at around eight months of age. However, dogs 

### runthe risk of death early on in their lives due to accidents. Llamas live for 10- 15years, with the average guard llama being two years old; however, the age ofllamashas been found to vary from less than one year old to 12 years, making a conservativeestimate oftheir useful life as a guard animal around 1 1 years. Donkeys are useful for 10-1 5 years, which is the longest useful life of any guard animal (Wilbanks, 1995).

Guard animals vary in terms oftheir suitability for certain herd sizes. Guard dogs are most effectivefor herds of sheep that are 200 head or less (or 200 acre fields). Llamas aremore adept at watching herds of 250-300 sheep (or 250-300 acres). Unlike guard dogs, which can be grouped together to watch sheep (1,000+in some instances), multiple guard llamashave not been found to be more effectivethan a single llama (Franklin and Powell, 1993 cited in Andelt, 2004)~The use ofllamas and donkeys is also somewhat lower in the Pacific states and West Virginia (areas with relatively high predation), and may be due to the generally smallerherd sizes in these states. A large guard animal for a flock of 30 to 40 sheep may simplynot be cost effective. Finally, guard llamas and donkeys are not a threat to non-target species,but there have been cases in which guard dogs have paired with wolves to prey on livestock (Andelt, 2004) or have preyed on wildlife (Larson, 2006).

An examinationofTable 13 suggests that the use of guard dogs is fairly consistentthroughout the United States, although BEAD views these numbers with caution. Without more information about the survey, it is not clear that guard dogs represent the types and uses discussed here. We also note that the use of llamas decreases as one moves south, where donkeys appear more favored. Llamas are Andean animals that arebest suited to high elevations and cooler temperatures similarto those found in the Mountain West and Northern Plains while donkeys thrive in the hot and arid desertregions ofthe southwestern deserts,. Llamas are not adapted to hot and dry conditions and are susceptibleto heat stress during the summer months; these conditions could lead to poor growth, illness, or even to the death ofthe animals. Recommended

-- - 6 Limited coverage data was available on guard donkeys.

27protection measures include shearing and providing abundant fresh water and shade, and even artificial ventilation. Such requirements may not make llamas a cost effectivemethod for predator control, especially when consideringthat their performance and ability to function as a guarding animals may falter when subjectto such stress (Free and Anderson, 2003).

b. l4giIance (Herding)

Thepresence of a herder alone may discouragepredators from initiating an attack. Skilled and alert herders can further discourage predationby rapidly taking protective measures if a predator approaches the flock. The employment of herders seems to have declined in recent years because of increasing costs and shortagesof well-trained personnel (Green et al., 2005). Accordingto USDA statistics, 6.6% of sheep operationsemployed herders to prevent predator losses in 1999 (USDA NASS, 2000), and 5.7% of opkations did so in 2004 (USDA NASS, 2005). Herders' services are cost-prohibitiveto someranchers (Shivik, 2003), and may be one reason that onlynine percent of sheep and goat producers used herders in 1984(Nass and Theade, 1984). Table 14presents the percentage of operations using herding and frequent checks by state in 2004.

It has been shown that herding leads to consistently smaller rates oflambkid predation relative to other, more commonpractices, such as fencing, shed lambing, and daily sheep checks. Specifically, in a study where the average rate of lambkid predation was greater than 5%, 89% ofproducers reduced predation to less than 5% using a herder (Nass and Theade, 1984). It has also been suggested that one ofthe most effective and cheapest ways to target problem coyotes is to equip a herder with a flat-shooting, scoped rifle. Since coyotesthat are seen near a flock are ones that tend to kill sheep, herding c& be considered a selective form of lethal control (McAdoo and Glimp, 2000).

The cost ofherding is a clear deterrentto its use. However, as the percentage of operations using herding as a means to prevent predator losses is low throughout the United States, certain areas that experience exceptionallyhigh rates ofpredation, such as Arizona, California, West Virginia, and the Mountain West, on average rely more heavily on herding.Table 14: Percent of Sheep Operations Using Herding, Frequent Checks, and Fencing to Prevent Predator Losses, 2004.



# I Northern plains 

# ' 4.4 15.2 19.9 2.5

State Arizona California Mountain West 

# ' Herding 11.6 10.0 10.4

Texas Plains Pacific East

Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas, Nebraska, and Oklahoma. 4 Oregon and Washington. 5 Illinois, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Missouri,New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. Frequent Checks 27.1 11.8 20.6

5.2 3.2

West Virginia United States

Herding is less used in cattleproduction, with 3.8% of cattle operations indicatingthat they use herders to prevent predator losses (USDA, 2006). More cattle operations, 21.8% conduct frequent checks, however, as a preventativemeasure. 3.9 5.9

c. Exclusion (Fencing) Fencing 40.1 71.9 45.2

16.7

5.4

Source: USDA NASS. 2005 14.2 5.7

Using fences to exclude predators can be an effective sheep protection technique. However, to be effective, the fencesmust be virtually coyoteproof. That is, they must not allow coyotesto go over, under, or through them at any time. Fences must be at least 5.5 ft tall to keep coyotes fromjumping over them. 

### An overhang on the outsideofthe fence would discourage climbing. To prevent coyotes from diggingunder them, fencescan be outfitted with apronsthat extend one foot into the ground. They should be inspected regularly in order to rapidly repair damaged sectionsor trim away vegetationthat may be growing too close, as it can be used by coyotesto bridge the fence. Portable fences are availablefor containing small flocks, and can alsobe electrified for additional protection. A major drawback of fencing as a sheep protection technique is its high maintenance cost. Fences work best for small operations and may be costprohibitive to construct and maintain. They may also be impractical when pastures or rangelands are extensive,when terrain is highly irregular,or when there is an abundance of vegetation. As for other predation management options, fencing works best when used with other management techniques. Deterrents 2.4 5.9 5.0

22.1 14.4

In a surveyby Nass and Theade (1988), woven wire fences are a popular method for reducing lambkid predation, with 100%of 95 surveyed producers in California, North Dakota, Oregon, and Texas using wire fences. However, it does not appear that this method is particularly effective, with 45% ofproducers reporting lambkid predation being greaterthan 5%. Table 14 32.0 46.1

65.1 14.0 0.8 1.3 58.7 51.4 2.2 2.4 67.3 52.5 1.3 2.2presents data from USDA on sheep operationsusing fencing. Much lower numbers are shown in Table 14 than in the Nass and Theade (1988) survey. A difficulty in interpreting any ofthese results is that it may be difficult to determine whether an operation identifies a practice specificallyfor predator control or whether the practice is part ofthe total production system.

In an interview of over 100 sheep producers in the PacificNorthwest by Nass and Theade (1988), electric fencing is shown to be a relatively successful method among these producers in reducing sheep predation, with a 91.4% decreasein the loss of sheep due to predation, from an average of 41 head lost per flockper year to an average of 3.5 annually. Overall, 45% of sheep producers interviewed in this study who had experienced sheep predation incurred none after installing fences. The studypoints out that although fences last an average of 20 years with proper maintenance, they are quite expensiveto install. 

### In 1983prices, they cost $554 per mile of fence in this region ($1,204 in 2008 dollars). With a mean coverageof 301 acres for an average flock size of 1,036 head, this indicatesthat the average cost to install fences for a sheep producer would be $4,170 ($9,069 in 2008 dollars) which may not be feasible for many producersin the Pacific Northwest. Fencing is likely to be infeasible for other regions ofthe United States, such as Texas, where sheep production tends to occur on the open range, making fencing impossible. Other limitations, such 

### as topography and flock size, can also influence the effectivenessof fencing. Issues such as these, along with other factors such as the life of the fence, its cost, the level ofpredation control desired, and the predation level being faced are all things a producer should reflect upon when consideringwhether or not fencingwould be a costeffective predation control option for them (O'Brien, 2002).

The installation and maintenanceof coyote-proof,net-wire fences is generally expensive and rarely used, except around confined spaces where there is a high stocking density (e.g. pens, corrals and feedlots). Although the use of fences does reduce predation, total exclusionof coyotes through fencing is unlikely, as some coyotes eventually learn how to breach fencesby diggingunder or by climbing over. Fencing is impractical where the area to be protected is extensive and the stocking density is low, such as in western range sheep operations (Wilbanks, 1995). Fencing for predator protection is used by 34% of cattle operations (USDA, 2006). Fencing is probably more feasible in concentrated dairy production than in extensive grazing operations for beef cattle.

One ofthe major drawbacksto fencing is that it acts as a physical barrier to many species and
can result in habitat fragmentation. In addition to short-termrisks associated with habitat fragmentation, such as food shortages, it can significantly reduce species and genetic diversity, which is ofutmost concern regarding the vitality ofthreatened and endangered species (Groom et al., 2005).dDeterrents

Sound and light producing devices can be used to deter predators, especially at night, when most predation occurs. One such device is the propane exploder or "gas cannon". This deviceuses a spark to ignite a charge ofpropane or acetylene into a firing chamber, producing a loud explosionthat resembles the firing of a 12-gaugeshotgun. Timers attachedto the device are used to trigger random or intermittentexplosions. A photo cell can be included to turn the system on at night. Changingits location every few days increasesits effectivenessas a predator deterrent. There are several battery-operated devicesthat create sound to deter coyote predation on livestock. For example, some emit the sound of barking hounds to scare away coyote. The most popular frightening device is the "Electronic Guard", which was developed by APHIS WS. This battery-operated device is available from the Pocatello Supply Depot and emits sound (sirens) and strobe lights, randomly or at regular intervals. It is activated at night by means of a photoelectric cell or by motion sensors

### in the area. Linhart et al. (1992) analyzed the effectiveness of this frightening device in deterring coyote predation in Western Colorado. The study found that, on average, sheep losses to coyotepredation in mountainous areas were reduced by 60% during the summer at a savingsof $2,400 per flock using 1983 and 1984market prices (6.6% of total lambs lost prior, 2.7% after the fightening devices were deployed). Tests conducted by the National Wildlife Research Center 

### (NWRC) indicatethat sheep predation can be reduced by an average of 80percent in range and field scenarios, and 60 percent in the mountains, supporting the findingsof Lindhart et al. (1992) (APHIS fact sheet, 2002). The Electronic Guard costs approximately$250. Although effective, the Electronic Guard is not intended for year round use since coyotes become conditioned to it and eventually ignore it. However, limiting its use to only the lambing
season can significantly reduce the number oflambskilled by coyotes. APHIS WS recommends that at least two guardsbe used for small, enclosed pastures (20-30 acres), while three to four should be used for larger, enclosed pastures (3 1-1 00 acres).Four or more should be used if a band has more than 1,000head of ewes and their lambs.

One common problem with any type of deterrentis that coyotes will eventually habituate to the stimulus in periods that may range from a weeks to months. As for other types ofpest problems, excessive reliance on any one type ofpest management technique deterrents will only provide limited or temporary protection in the long run. Another drawback inherent to these devices is that the loud soundsproduced can be disturbingto neighbors and other wildlife in the area. Deterrents, which generallyhave fixed locations, will also not work well with large flocks on extensiverangeland. The relativelyhigh use of deterrents in the Mountain West (Table 14) would seem to refute this hypothesis, but the average for the region is skewed by heavy use in New Mexico.

Deterrents are also rarely used in cattleproduction, but as in sheep production, is common in Idaho and New Mexico, where respectively20.6% and 25.5% of operationsreport using such tactics (USDA, 2006).

### e. Husbandry management practices Producers may also rely on a variety of husbandry management practices to minimize livestock exposure to predation, including:

i.Avoiding high predation areas Coyote depredation may be greater in certain areas due to factors such as an abundance of vegetation or terrain characteristicsthat facilitate stalking and approaching prey. Identifjmg and avoiding those areas may result in fewer livestock lost. However, this approach may not always be practical because it may interfere with pasture utilization and other management practices.

ii. Nightpenning Sincemost coyote attacks occur at night, herding sheepback into enclosures nightly is another technique that reduces the risk of predation. Keeping a light on over such enclosures further discouragespotential predators from approaching. As for most of the other management practices discussed here, night penning by itself does not provide full protection from predators. Rather, it is the adoption of several complementary management practices that have the greatest likelihood of minimizing predation. Night penning, like herding, is used less often than methods such as fencing, shed lambing, and daily checks. Although no definitive studieswere found in this review, it has been suggested that this method is much more effectivethan such alternatives. Nass et al. (1984) found that although only 12% of surveyed producerspenned at night, 73% ofthem began to experience less than a 5% rate oflivestock predation. In 2004, nearly one-third ofproducers indicated that they utilized night penning (USDA NASS, 2005). See Table 15. For large flocks and extensive grazing, night penning may only be practical for short periods during the lambing season. Night penning may also be impractical for cattle operations,except for dairy cattle, because most depend on extensive grazing. Pens or corrals for cattle would also entail higher costs than for sheep. USDA (2006) reports less than 10% of cattle operations practice night penning to prevent predator losses.

iii. Shed lambing Since coyotes that prey on sheep generally target lambs, keeping ewes that are about to give birth in protected enclosureswould reduce the risk of predation. Because of logistics and labor costs, this practice may be more suitable for smallerflocks.

This method is highly effective, and can result in lamb rates of 150%to 200%, compared to 60% to 130% on the range.7 The benefits of shed lambing extendbeyond reducing predation. It can reduce the loss of lambs to risks such as disease and poor weather conditions and can also increase the weight of a weaned lamb by 20% in comparison to pasture or range lambing. Despite these benefits, shed lambing remains difficultto implement given its extraordinarilyhigh costs. Ifpredation is the only concern, studies suggest that shed lambing is only cost effectiveif

7 This is accounting for twins.more than 20% of lambs are lost to predation (Walker et al., 1993;Burfening and Van Horn, 1993; McAdoo and Glimp, 2000).

Table 15: Percent of Sheep Operations Using Husbandry Management Practices to Prevent Predator Losses. 2004. State Arizona California Night Penning

Mountain West 

# ' Northern Plains 27.8 35.6

Texas Plains Shed Lambing

41.9 38.0

pacific East

I - I - 1 - I Source: USDA NASS, 2005 Sanitation 32.2 33.8

23.7 41.5

West Virginia United States
Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming. North Dakota and South Dakota. Kansas,Nebraska, and Oklahoma. 4 Oregon and Washington. Illinois, Indiana, Iowa, Kentucky, Maryland,Michigan, Minnesota, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and Wisconsin. 4.2 12.5 39.9 30.7

38.7 30.0

iv. Sanitation (carcass removal) 22.6 12.1 16.3 30.1

12.0 32.9

Sanitation is the removal of dead livestock to avoid attracting predators to the area. This technique is more suitable to smaller operations,and is less practical for larger operationswith extensivepasture. However, 16.5% of cattle operationspractice sanitationand 19.6% of operationsreport culling their herds of old, sick, or otherwise weak animals (USDA, 2006). 4.7 6.5 43.7 3 1.6

v.Monitoring sheep numbers (record keeping) 25.1 9.8 22.8 30.8

Maintaining a strict control of sheepnumbers in order to rapidly note if sheep are missing is another management techniquethat provides an early warning ofpredator activity, thus allowing ranchers to take appropriateprotection actions before too many sheep are lost. It is not, however, a protectivemeasure. 10.6 11.7

vi.Altering breeding timesfall lambing) Therisk of coyote predation on lambs tends to increaseduring the spring and summer, when coyotes whelp and rear their pups. Although spring lambing coincides with the natural breeding and lambing seasons, this is also the season when risk of coyote predation is highest for lambs. Spring lambs are born to ewesbred during Septemberthrough November, but for ewes to lamb in the fall, they must be bred in May and June. Most lambsborn in the fall are larger and less vulnerableto predation during the peak coyotepredation period. A major drawback ofthis technique is that the natural estrus cycle of ewes must be artificiallyaltered. Another limitationis that fall lambing may be not be compatible with marketing concerns or range and weather conditions.


### J Experimental Techniques

Various repellentshave been evaluated in the past with limited success. Treating sheep collars with chemical repellents, such as capsaicin,has not been found to effectively deter predation, since after its first exposure, coyotes tend to avoid the neck region and attack unprotected parts of sheep, such as the hind-quarters. Plastic collars designed to protect the neck region of sheep from attacks fromjackals have been tested in SouthAfrica. Even training collars have been tested to teach coyotes not to attack sheep (Shivik, 2003). Although a detailed review is not provided here, Andelt et al. (1999) reviewed the training collarmethod, and found that over a 22 week period, the collars averted all 13 attempted attacks on lambsby nine coyotes (all of which were noted for previous lamb killings). However, it is not likely that many livestock producers will spend the effort to capture a coyote in order to collar and release it.


### V. Discussion and Conclusions

Conflictsbetween the livestock industry and mammalian carnivores, especiallycoyotes, are often unavoidable as livestock and potential predators frequently occupy the same territory. Predation problems seem to be highly variable and localized, and can be rare or absent in some operations and moderate to severe in others. The petitioners allege that the benefits ofM-44 and LPCs are low, in part, because other means of predator control, particularlynon-lethal means, are effective. The petition cites a recent newspaper article describing the success of a program in Marin County, California, as evidence that eliminatingthe use ofM-44 and LPCs would not result in substantial impacts to livestock producers (Brenner, 2005). The article claims that the county initiated a completely non-lethal program consistingof guard animals, electric fencing, deterrent devices, and other practices. The county agricultural commission is quoted as reporting a decline in predator losses from 5% of stock to 2.2%. Brenner (2005) and Fox (2006) indicatethat the Marin County program replaced the use ofM-44 and 1080. However, use ofthese measures, along with certain traps, had been banned in 1998by a state-wide referendum. Fox (2006) also reports that, while the Marin County program ended funding for federal trapping assistance, ranchers can use lethal measures, including hunting and trapping, on their own lands.

Larson (2006) disputes some ofthe claims made about the program. While losses were low the initial year ofthe program, they appear to have returned to levels observed in previous years. Losses on individual ranches have been over 18% in some years. Moreover, reported losses only include participatingranches, which number about 18 out of 29 in the county (Brenner, 2005). Larson also presents anecdotal evidencethat the number of coyotes taken may have increased as individual producers continue to employ lethal measures. Finally, Larson shows that costs to the county have increasedunder the new program, in part because the county compensates ranchers for lost sheep at their market value.It is unlikely that a program such as that in Marin County, even assuming it is as effective as proponents say, could be extended to other areas. Timm and Connolly (2001)report that the LPC was the most effectivemeans ofprotecting sheep at the Hopland Research and Extension Center in Mendocino County, just north ofMarin. They report problems with guard animals in terms of effectiveness, in part because ofrugged terrain and large pastures. They also report a decline in wild turkeys associatedwith the use of guard dogs and several deer killed by the dogs. Woven-wire fencing with a ground-level electrifiedwire proved ineffective. High-tensile electric fencingreduced predation but proved costly to maintain (Timm and Connolly, 2001). BEAD concludesthat a concerted program of non-lethal measures can be effective with smaller flocks and small pastures ofrelatively even terrain. However, this does not correspond to much ofthe Mountain West and Texas, where large flocks and extensive grazing are practiced.

Comments submitted to the Agency suggest that many producers rely on a mix ofpredator management techniques,both lethal and nonlethal, to protect livestock from predation by coyotes and dogs. The use of any combination ofpredator control techniques is sometimes described in the literature as integrated predator management ("IPM"). For instance, in discussing the role of guarding animals,Wilbanks (1995) states that donkeys are 

### "... compatible with most traditional methods ofpredator control and can be used in an integrated predator managementprogram." Similarly, according to Franklin and Powell (1994), the best protection to livestock is accomplished through an IPM program that includesboth preventive (i.e., nonlethal methods) and selected control methods, since no singlemethod is fully effectiveby itself. One example of IPM working can be seen in West Virginia. The coyote population has been increasing during the past several years in the southern and southwestern regions ofthis state due to the extinction ofthe eastern wolf and the re-establishment of deer herds (West Virginia DNR). In West Virginia, sheep often graze on semi-isolated mountain pastures without human or animal guardians (Houben, 2004), and are likely at risk of predation. In the 1990s,USDAIAPHIS Wildlife Servicesimplemented predator management programs in West Virginia using both nonlethal and lethal techniques, which included the use of LPCs. From 2000 to 2002, approximately 12% of sheepproducers participated in the program, with seemingly positive results in terms ofreducing sheep and lamb lost to predation. However, it cannot be assumed that such success can be achieved for all producers for reasons such as variations in topography and predation rates; therefore, lethal methods, includingthe use of M-44s and 1080s,will likely need to be incorporated into many producers IPM programs in order for them to obtain reductions in livestock predation.

Comments submitted to the Agency indicate that while some livestock producers do not use M44 devices or LPCs, others consider them to be essential to the viability oftheir operations. A number ofproducers affirm that these tools are used only as an option of last resort to be used when all other predator control attemptshave failed. Others consider them essential components oftheir overall predator management programs. Because the intensity of predation on sheep, goats, and cattle depends on factors such as terrain, vegetation, pasture location and size, flockJherdsize, predator abundance,prevalence of the predator's natural prey, choice ofprey control measures, and the unique characteristicsof each livestock operation, producers' experienceswith predation would be expected to vary significantly. Furthermore, considering the many factors that can affect predation, it is unlikely that any one combinationofpredatormanagement techniques will work equally well in all situations. Thus, when or where predation is severe, producers may rely more on lethal methodsthan in situations where the predator pressure is relatively low. When non-lethal control measures fail to prevent sheep losses, producers inevitablyturn to lethal methods, and many have found the M-44 device to be effective and convenient, especiallywhen aerial hunting is impractical due to heavy plant cover or when freezing conditionspreclude the use of traps and snares.
While the M-44 ejectoris designed to attract canids, especially coyotes, it cannot discriminate between coyotesthat prey on sheep and those that do not. However, with the exceptionof denning and hunting, alternativelethal control methods (hunting, trapping, snaring) are not necessarily any more selectivethan M-44s in terms oftaking non-target species. Hunters, including those practicing denning, may rarely kill other species,but they likely kill coyotesthat
are not preying on sheep. LPC's are the most selectivemeans, 

### as they kill only the attacking animal.
Overall, it is evident that M-44 and LPC devices provide benefits to livestock producers, particular producers of sheep and goats but also of cattle, and if users had to rely on the available alternatives, they would likely incur higher costs and more predation. 

### In light ofthe competitive nature ofthe industry, such a change could forceproducers out ofbusiness.



### VI. References
Andeit, W. 1984. "Livestock GuardingDogs Protect Domestic Sheep from Coyote Predation in Kansas". Great Plains Wildlife Damage Control Workshop Proceedings
Andeit, W. 1992. "Effectiveness of Livestock Guarding Dogs for ReducingPredation on Domestic Sheep." Wildlife SocietyBulletin 20(1): 55-62.
Andeit, W. 2003. "Use of Livestock GuardingAnimals to Reduce Predation on Livestock." American Sheep Industry Association.
Andeit, W. 2004a. "Use of Livestock GuardingAnimals to Reduce Predation on Livestock." WildlifeDamage Management, Internet Center for Sheep and Goat Research Journal, University ofNebraska, Lincoln.
Andelt, W. 2004b. "Livestock Guard Dogs, Llamas, and Donkey." Colorado StateUniversity Agircultural Extension, Paper No. 1.2 1 8. 

### http:~lwww.ext.colostate.edul~ubs/livestO 1218.html.
Andeit, W., R. Phillips, K. Gruver, and J. Guthrie. 1999. "CoyotePredation on Domestic Sheep Deterred with ElectronicDog-Training Collar." Wildlife SocietyBulletin 27(1): 12-1 8.

APHIS. 2002. "The M-44 Sodium Cyanide Ejector Mechanism, Factsheet." 

### http:~/www.a~his.usda.g~vI1pa/pubs/fsheet faci noticdfs wsm44.~dEArieti, Ruth. 2008. "Changes in the Sheep Industry in the United States." National Academy of Science, 2008. http://dels.nas.edu/dels/rpt briefs/SheepFinal.~df: Berger, K. M. 2006. "Carnivore-LivestockConflicts:Effects of Subsidized Predator Control and Economic Correlates on the Sheep Industry." Conservation Biology 20(3): 751-761.
Bodenchuk, M., R. Mason, and W. Pitt. 2000. "Economics of Predation Management in Relation to Agriculture, Wildlife, and Human Health and Safety." USDA National Wildlife Research Center Symposia: Human Conflictswith Wildlife: Economic Considerations University ofNebraska, Lincoln.
Brenner, K. 2005. "CoyotesGet a Reprieve." Marin IndependentJournal,November 13. Reprinted in Wild Guardian, SpringlSumrner2006, at http:/Iwww

### .~redatorconservation.ord%2OMedia~PDF/WildGuardianSpring06.pdE
Comer, M., M. Jaeger, T. Weller, and D. McCullough. 1998. "Effect of Coyote Removal on SheepDepredation in Northern California." The Journal ofWildlife Management 62(2): 690-699. Connolly, G. 1981. "U.S Fish and Wildlife ServiceCoyote Control Research." D. W. R. Center. Twin Falls, Idaho. Connolly, G. 1988. "M-44 Sodium Cyanide Ejectors in the Animal Damage Control Program, 1976-1986." Proceedings of the Thirteenth Vertebrate Pest Conference. Connolly, G. and R. Burns. 1990. "Efficacy of Compound 1080Livestock Protection Collars for Killing Coyotesthat Attack Sheep." Proceedings ofthe Fourteenth VertebratePest Conference 1 990, University ofNebraska, Lincoln.

EPA. 1994. "Reregistration Eligibility Decision (RED): Sodium Cyanide. Office of Prevention, Pesticides, and Toxic Substances (OPPTS)." EPA 738-R-94-020. At: httD://~~~.e~a.~ov/oppsrrdl fREDd3086.pdf

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