Yesterday I was reading an article of utter nonsense published in a small Maine town newspaper about coyote behavior.  Of course the article was all about the love of the nasty, diseased animal and the call for its protection “because it is an important necessity for a healthy ecosystem.”  Unfortunately the writer appears to have gotten 100% of their education from the proven and admitted make believe of Farley Mowat’s Never Cry Wolf. 

Mowat laced his book of fiction with make believe nonsense about how wolves and coyotes only eat mice and other small rodents.  The author of the Maine piece tells the same fairy tale about Maine’s coyotes: “To clarify, coyotes primarily feed on mice and other rodents…” The myth if further perpetuated by stating: “While coyotes do occasionally eat fawns and sick deer…”

Coyotes are basically garbage collectors that will eat anything…and by that I mean anything.  When hungry enough, they will eat mud in order to stop the hunger in their guts.  But this author obviously doesn’t get around much.  Coyotes in Maine are a mixed hybrid animal, a cross breeding of an invasive coyote, wolf, and domestic dog.  Because of this, the wild canine in the Maine woods is not like a typical coyote.  Maine’s coyotes feed on deer, yes, adult deer too, in regular fashion.  To state that coyotes feed primarily on mice and other small rodents is patently false. 

The purpose of the author making this statement is to claim that because coyotes eat mice, we need to protect them because mice are what carry the ticks that cause and spread Lyme disease. 

There’s a problem with that scenario.  If anyone does any honest and complete research on the behavior of coyotes and the results of their behavior, they would know that the meal of the Maine coyote hybrid includes such animals as foxes and other canines and felines that truly do feed on the mice that perpetuate Lyme.  The more coyotes, the fewer foxes and thus, because honestly coyotes don’t primarily feed on mice and small rodents, having more coyotes results in fewer animals that do kill the mice and thus the possibility exists that the prevalence of Lyme grows. 

It should also be noted that while some choose to believe that the coyote makes for a healthier ecosystem, the reality is far from healthy.  It has been proven that coyotes carry as many as 50 different diseases and viruses.  Maine also has detected the presence of “lung worm” in moose.  Lung worm, in this case Echinococcus granulosus (E.g.) is the result of the presence of wild canines.  E.g. can be contracted by humans and can be deadly.  Wild ungulates, such as deer and moose, pick up the disease by grazing around coyote scat where the tiny infectious spores are found.  These spores are highly viable and thus the increase in the spread of the disease.  In short, the more coyotes roaming the countryside, the higher the threat of disease.  E.g. is not a direct killer of deer and moose (livestock also) but restricts their ability to escape large predators because of cysts that can grow on lungs and other internal organs. 

The author points an accusatory finger at the Maine Department of Inland Fisheries and Wildlife (MDIFW) for lying about its “responsible and science-based stewardship” when it comes to the management and control of coyotes.  I find is amazing that simply because a person does not agree with the “responsible and science-based stewardship” of the MDIFW (in other words the department may not be all in with complete animal protection and natural wildlife management), they are labeled irresponsible and that their practices aren’t science-based.  In fact, regardless of the fact that MDIFW spends far too much time trying to appease the social demands of lunatics who think coyotes will stop Lyme disease, the department’s efforts in selective coyote control and the allowing of coyote hunting derbies, while perhaps not a favorite tool for this necessary control, it is something that must be done in order to be “responsible and science-based” in the care and management of other wildlife species. 

No matter how much anyone wants to read and believe Farley Mowat’s nonsense, it doesn’t change reality.  Nature does not regulate itself in the Nirvanic way the uninformed want to believe.  The author states that if we would leave the coyote along it would regulate itself.  Obviously, the author has never seen the predator pits of death, destruction, and scarcity that predator protection causes. 

If we want to enjoy the wildlife and its abundance, real responsible and science-based management and control is necessary. 

To go along with the age old saying that statistics prove that statistics can prove anything, the same is evident when it comes to predator/prey relationships.  Simply pick the “expert” advice and opinions from those who have theories and “suggestions” that, when cherry-picked appropriately, will neatly fit into an agenda-driven narrative, and you have an instant predator/prey relationship that works for you. 

Recently I was reading what is really a very ignorantly compiled bit of broad-brushed nonsense about how coyote control doesn’t work (for the purpose of providing enough deer for hunting).  Void of any specific information of just how any sort of coyote control was, is, or might be implemented (it is crucial in attempting to make determinations that result in such claims as “don’t work”) to make the statement that coyote control doesn’t work is dishonest at best. 

Not to belabor the issue of whether or not coyote control works or doesn’t work, perhaps missing from the writer’s obvious hatred for those who choose to hunt and eat natural food, is the simple fact that no example of whether coyote control works, or is even needed, is ever considered before, during, or after ranting on about a call for protection of large predators as though it is something that should never be done and by not doing it everything lives in perfect harmony.  What nonsense.  And it’s so tiring to be subjected to the same nonsense repeatedly. 

This morning I was reading a Ph.D. college thesis where a person chose to study the predator/prey relationship between coyotes and whitetail deer in the Chicago area.  The Abstract tells us a few very important things.  First, that coyotes were the cause of 77.8% of whitetail deer fawn mortality.  Second, that there are so many coyotes and deer in this study area that habitats unavoidably overlap, and three, coyote seem to prefer to prey mostly on fawn deer and not adult deer. 

It would be ridiculous to make any kind of suggestion about whether coyote control would work or not work in this situation or for the reason anyone might suggest coyote control.  As far as hunting goes, if there are this many deer, what coyotes do to only the deer herd is probably immaterial.  There may be other collateral damage that is not being considered. 

Another example of why broad-brushed accusations and conclusions are ignorant is the fact that an agenda-driven person might use this thesis to prove that coyotes only prey on fawn deer.  In this case, because of an overblown deer population and the fact that coyotes, like all large predators, are opportunistic hunters, i.e. that they simply kill and eat the most easily attained prey.  In this case, it is generally easier to take down a fawn deer than an adult deer. 

In a different scenario, one that could very easily be found on the Maine landscape, where in much of the state there is a definite scarcity of deer and an abundance of coyotes, a hungry coyote or pack of coyotes can and do take down the biggest and healthiest of adult deer. 

To claim predator control doesn’t work, based on some hyped up theory about reproductive behavior response, reveals a person’s desire to promote their own ideology at the expense of denying others the opportunity to promote surplus game management for consumptive use, a use that has been around since the beginning of time and this uncalled for totalitarian action coming at a time when people are in quest of natural, more healthy, food. 

The writer who claims that predator control doesn’t work, was pointing a finger at how Maine manages its deer herd which includes a degree of coyote control.  Again, void of specificity and an understanding of how, when, and where predator control would be effective, the author chooses to wrongfully claim that control doesn’t work. 

In Maine’s case, much of the coyote control takes place during winter, in deer wintering areas, where coyotes often make those areas blood baths.  Whether there’s any so-called reproductive behavioral response in coyotes to run out and have more pups to replace those taken during control actions, matters little.  It is known and understood that any effective control must be ongoing and targeted, thus the reason the Department of Inland Fisheries and Wildlife (MDIFW) implements the coyote control. 

The foundation of the call for coyote control in Maine is based upon the fact that, unlike the Chicago region, much of Maine has a very scarce deer population.  Common sense, often lacking these days, should tell us that deer venison on the table is of a higher value to the consumer than a nasty, disease carrying wild dog.  I, like many others, would like to improve our odds of filling our freezers for the winter, and thus we call for targeted coyote control in deer wintering areas in order to assist in the management of a few more deer.  I would like to take the opportunity to say that for many in Maine, deer meat is an essential to providing sustenance.  In addition, I would like to be able to choose to hunt deer, bear, and moose as a healthy alternative to store-bought meat. 

If Maine had, statewide, the same deer density as is found in portions of Central Maine, coyote mortality on deer would mostly go unnoticed.  Such is not the case. 

Because we live in a post normal existence, where science is about predetermined outcomes that fit agendas and drive narratives, anyone can pick and choose theories, perspectives, and suggestions to support any claim they wish.  In this case: Coyote control doesn’t work. 

In the same vein, I can claim that coyote control does work when it is applied scientifically in those regions where it becomes necessary to sustain a deer population. 

Here we go with one more “study” that “suggests” that a reduction in the presence of foxes and perhaps other smaller predators who feast on mice is causing an increase in those rodents/mice that carry and spread diseases such as Lyme Disease. 

For at least 6 years there have been ample studies suggesting the same thing.  However, one of the problems associated with these so-called “studies” is that in one form or another all causes not desired by the individual or group of individuals seeking desired results, are blamed on “Climate Change,” i.e. Global Warming. 

When reading the latest report about predators and the spread of disease, I recalled that I had read not that long ago about Joh Lund, publisher of the Maine Sportsman Magazine stating that he tended to agree that a reduction in the number of foxes could be the root cause of an increase in Lyme and other diseases carried and spread by small rodents like the white-footed mouse that carries Lyme.  Lund’s hypothesis is that the reduction of foxes is caused by direct competition from coyotes.  With Maine and other states experiencing ample growth in the number of coyotes, wolves, and coywolves, the result is a sharp reduction in foxes and other smaller prey responsible for keeping in check the rodents that carry disease. 

Perhaps we can just as easily blame the increased spread of diseases, such as Lyme disease, on a misguided approach to wildlife management.  So long as wildlife managers insist that the crux of their decision making will be based upon social demands, i.e. the protection of large predators, then we cannot expect any changes that might result in the reduction of disease-carrying rodents. 

To go along with this misguided approach to wildlife management, there are ample groups and individuals with pet projects aimed at protecting one species of animal over the other with all the fabricated excuses for doing so.  The larger and wealthier the animal protection group is the more pressure they can put on wildlife managers who insist on making their decisions based on social demands. 

Most state wildlife managing departments openly invite this kind of pressure to be brought on themselves by publicly announcing that they will cave into social demands regardless of any scientific knowledge. 

At work, we have those who believe that killing off large numbers of deer will reduce the presence and spread of Lyme Disease.  We also have those who love coyotes, wolves, coywolves, and all other breeds and mixed breeds of wild dogs who refuse to allow any managers to necessarily go about killing those animals in order to find some kind of balance that should be desired for a healthy ecosystem and thus creating an atmosphere where people are less likely to get sick. 

Perhaps lost in all this modern-day Voodoo Science and Romance Biology is the fact that animals are nasty and spread diseases.  I don’t personally believe that this creation was intended to live in our homes or that we should be demanding that disease-spreading animals of any kind should be protected.  This misguided hogwash about Nature’s Balance is causing all kinds of problems, the majority of which are not being talked about and people refuse to listen.  It’s easier to blame all problems on Climate Change than to address these issues responsibly. 

If wildlife biologists and managers, who aren’t completely brainwashed into this modern wildlife management hocus-pocus, were allowed to manage wildlife from a real scientific perspective and an understanding that many of these animals are a resource intended for the people, and void of perverted social demands, perhaps then and only then will be able to do a better job.  Until that happens – and I’m not holding my breath, – we can expect more disease problems and safety threats to the people who want to pursue Life, Liberty, and Happiness. 

I recently thanked the St. Paul Pioneer Press and one of its writers for exposing the controversy surrounding growing complaints in St. Paul, Minnesota regarding the presence of and conflicts with urban coyotes.  Phone calls by the author of the article to the St. Paul Animal Control Supervisor; who was quoted as saying, “It speaks well for our city that wild animals choose to live here”; had gone unanswered.  The writer noted that, “Most of us don’t want coyotes, only to discover we have as our animal-control supervisor a woman with a Golden Book view of wildlife” and wherein “at night all the creatures gather around a fire and the raccoons provide for story time.” 

I noted the similarities between this urban newspaperman and his coyote concerns in the face of a city government bureaucracy that disdains to recognize or address his interests and the drama taking place in rural America between rural residents concerned with wolves and grizzly bears in settled landscapes in the face of an arrogant “Deep State” in Washington, DC and state wildlife agencies that have become little more than subcontractors to federal bureaucrats and agents of the same environmental/animal rights agendas exposed in the St. Paul newspaper. 

My “thank you” to the newspaper and the writer took the form of a Letter to the Editor that was recently published in the Sunday edition.  It was placed in between a letter from a St. Paul lady that thought she was, “fortunate to live with a National Park – and its attendant beauties, including wildlife – running through our midst”, and an instructive wildlife letter from a lady assistant professor of environmental education at a local University. 

The latter letter from the assistant professor brought to my attention two things.  One was a silly and contradictory modernistic biological theory justifying coyotes as beneficial to urban landscapes reminiscent of the after-the-fact of introduction of wolves that, “wolves restore willows along streams” nonsense.  She opined that:

“When there are coyotes in an urban area, there are fewer skunks, feral cats, and even foxes.  Not because the coyotes are tearing them apart, but because of something known as ‘competitive exclusion’ – when more than one species relies on the same food source in a given area, competition for that food source becomes a limiting factor, driving out competitors (i.e. causing the other species to look for food and shelter elsewhere).  The result is a stronger, more robust and diverse ecosystem – more plant species, bird and small mammal species.” 

According to this “something known as ‘competitive exclusion’”; “driving out competitors (i.e. causing the other species to look for food and shelter elsewhere)” makes, “a stronger, more robust and diverse ecosystem – more plant species, bird and small mammal species.”  Is it me or do others wonder how making less of some predator species probably makes for more of the winning predator (in this case coyotes) and this then makes more and hungrier top predators to decimate the prey species ever more efficiently and not a“stronger, more robust and diverse ecosystem” whatever “stronger” and “more robust” connote?  The contradiction here is all the more regrettable when spewed by a professor at a University; even when dressed up with animal rights drivel about how coyotes do not tear apart “skunks, feral cats, and even foxes” but merely drive out competitors “(i.e. causing the other species to look for food and shelter elsewhere) one must assume here in some sort of “Grapes of Wrath” convoy into oblivion. 

The second thing that caught my eye was her comment that:

“St. Paul doesn’t have a coyote problem.  The city’s approach to coyotes hardly represents the ‘Golden Book view of wildlife’ that Soucheray (i.e. the newspaperman) claims.  It uses science to inform policy and aims to educate the public so they can form educated opinions based on sound reasoning, evidence and data.” 

Just as with so much of the “science” and “good intentions” surrounding wolves and grizzly bears in settled landscapes this is hilarious nonsense attempting to eliminate any opposition to whatever is imposed by bureaucrat/ideologues with government power based on animal rights and preferences.  You have no right to question the fact that the city Animal Control lady won’t return your calls and answer questions; she is rightly busy “educating the public”.  You have only uneducated opinions and we are tasked with getting you to ratify (our) “educated opinions based on sound reasoning, evidence and data.”  Just as with calling someone not supportive of what you are saying or doing a “racist”, or “misogynist”, or “Islamaphobe”, or “homophobe”, etc.;  environmental/animal rights ideologues categorize troublesome citizens as “uninformed”, “uneducated”, “questioning ‘science’”, and incapable of basing opinions “on sound reasoning, evidence and data.”  Methinks the ladies should first inform the “public” rather than hiding from and disparaging a “public” that deigns to question their brilliance and chicanery. 

Lastly, the other urban lady that imagines she lives in a “National Park”“and its attendant beauties” closed her letter with:

By all means be on the watch for coyotes.  Also dogs, cars, cyclists, tweeting while walking, ticks, needles, poison ivy, storm warnings, and Archie Bunker reruns.  Danger, as well as beauty, is everywhere.  You’ll find what you seek.” 

Setting aside the sarcasm here, remember this is the urban area of Minnesota and there is perhaps no more liberal/progressive political concentration in America.  When you compare the newspaperman of the paper to “Archie Bunker reruns”, you have destroyed any credibility he might have with 75 to 80% of the readers.  In Minnesota, such an epithet is a classic “dog whistle” with a double meaning ending all discussion. 

As I mulled over these three ladies (one hiding in her office, another preaching nouveau biology to justify the unjustifiable, and the third in her imaginary ecosystem all too glad to disparage anyone questioning her nature beliefs) I was reminded of the 3 witches in Macbeth reciting their famous ditty. 

‘Double, double toil and trouble, fire burn and cauldron bubble’ are two of the most famous lines in English literature.  These lines show how what the witches say can have double meanings and can be contradictory.  The three ladies in St. Paul exhibit all of the misleading perfidy and disdain for others that we see in Macbeth and nationally regarding wolves and grizzly bears in settled landscapes and as with Macbeth they will lead us into great harm as long as we let them intimidate us and mislead others. 

For your edification here is the whole poem from Macbeth that the witches, speaking of animals by the way, spoke that gave them a place in infamy. 

For my money, the three St. Paul ladies should keep their “charms” to themselves. 

Jim Beers

10 August 2018

If you found this worthwhile, please share it with others.  Thanks. 

Jim Beers is a retired US Fish & Wildlife Service Wildlife Biologist, Special Agent, Refuge Manager, Wetlands Biologist, and Congressional Fellow.  He was stationed in North Dakota, Minnesota, Nebraska, New York City, and Washington DC.  He also served as a US Navy Line Officer in the western Pacific and on Adak, Alaska in the Aleutian Islands.  He has worked for the Utah Fish & Game, Minneapolis Police Department, and as a Security Supervisor in Washington, DC.  He testified three times before Congress; twice regarding the theft by the US Fish & Wildlife Service of $45 to 60 Million from State fish and wildlife funds and once in opposition to expanding Federal Invasive Species authority.  He resides in Eagan, Minnesota with his wife of many decades. 

*Editor’s Note* – If you were to read and/or listen to the Press about this proposal, you’d think the end of the world has come.  The Associated Press released a piece of lying, sensational, emotional drivel that is probably far from to the truth of what is really taking place. 

In brief, the proposal repeals most of the bans Obama placed on hunting and methods of hunting on Alaska public lands.  This proposal puts much more control of how wildlife is managed in Alaska back in the hands of state wildlife managers and out of the hands of bureaucratic morons in Washington and their Environmentalist buddies. 

Generally speaking, state wildlife managers have a better idea of how their wildlife should be managed and they need tools available to them to do that.  It doesn’t necessarily mean all those hunting and trapping methods become free range.  To state otherwise is irresponsible, emotional, and borders on criminal. 

However, below is the actual proposal as can be found in the Federal Register.  Unlike the Press, who NEVER provide links to the actual resource out of fear you might read it and discover their lies, I am posting it below for you to read and decide for yourself if we are all gonna die. 

Action

Proposed rule. 

Summary

The National Park Service proposes to amend its regulations for sport hunting and trapping in national preserves in Alaska.  This proposed rule would remove a regulatory provision issued by the National Park Service in 2015 that prohibited certain sport hunting practices that are otherwise permitted by the State of Alaska.  These proposed changes are consistent with Secretary of the Interior Orders 3347 and 3356. 

Dates

Comments on the proposed rule must be received by 11:59 p.m. EST on July 23, 2018. 

Addresses

You may submit comments, identified by Regulation Identifier Number (RIN) 1024-AE38, by either of the following methods:

Instructions: Comments will not be accepted by fax, email, or in any way other than those specified above.  All submissions received must include the words “National Park Service” or “NPS” and must include the docket number or RIN (1024-AE38) for this rulemaking.  Comments received will be posted without change to http://www.regulations.gov,including any personal information provided. 

Docket: For access to the docket to read background documents or comments received, go to http://www.regulations.gov. 

For Further Information Contact

Supplementary Information

Background

On October 23, 2015, the National Park Service (NPS) published a final rule (Final Rule) to amend its regulations for sport hunting and trapping in national preserves in Alaska (80 FR 64325).  The Final Rule codified prohibitions on certain types of harvest practices that are otherwise permitted by the State of Alaska.  The practices are: Taking any black bear, including cubs and sows with cubs, with artificial light at den sites; harvesting brown bears over bait; taking wolves and coyotes (including pups) during the denning season (between May 1 and August 9); taking swimming caribou; taking caribou from motorboats under power; taking black bears over bait; and using dogs to hunt black bears.  This rule is inconsistent with State of Alaska’s hunting regulations found at 5 AAC Part 85. 

Since the publication of the Final Rule, the Secretary of the Interior issued two Secretarial Orders regarding how the Department of the Interior should manage recreational hunting and trapping in the lands and waters it administers, and directing greater collaboration with state, tribe, and territorial partners in doing so. 

On March 2, 2017, Secretary Zinke signed Secretarial Order 3347, Conservation Stewardship and Outdoor Recreation.  Part of the stated purpose of Secretarial Order 3347 is to increase outdoor recreation and improve the management of game species and their habitat.  Secretarial Order 3347 directs the Department of the Interior to identify specific actions to (1) expand access significantly for recreational hunting and fishing on public lands; and (2) improve recreational hunting and fishing cooperation, consultation, and communication with state wildlife managers. 

On September 15, 2017, Secretary Zinke signed Secretarial Order 3356, Hunting, Fishing, Recreational Shooting, and Wildlife Conservation Opportunities and Coordination with State, Tribes, and Territories.  Part of the stated purpose of Secretarial Order 3356 is to increase outdoor recreation opportunities for all Americans in greater collaboration with state partners, including opportunities to hunt.  Secretarial Order 3356 directs the NPS to (1) identify whether hunting opportunities on Department lands could be expanded; (2) work cooperatively with state wildlife agencies to enhance their access to Department lands for wildlife management actions; (3) work cooperatively with state wildlife agencies to ensure that hunting regulations for Department lands and waters complement the regulations on the surrounding lands and waters; and (4) work in close coordination and cooperation with the appropriate state wildlife agency to begin the necessary process to modify regulations in order to advance shared wildlife conservation goals/objectives that align predator management programs, seasons, and methods of take permitted on all Department-managed lands and waters with corresponding programs, seasons, and methods established by state wildlife management agencies. 

The purpose of this proposed rule is to align sport hunting regulations in national preserves in Alaska with State of Alaska regulations and to enhance consistency with harvest regulations on surrounding non-federal lands and waters in furtherance of Secretarial Orders 3347 and 3356.  The proposed rule would apply the State of Alaska’s hunting regulations to national preserve lands, with limited exceptions found elsewhere in NPS regulations.  See, e.g., 36 CFR 13.42(d). 

The 2015 Final Rule prohibits the hunting practices otherwise permitted by the State of Alaska because NPS found those practices: (1) To have intent or potential to alter or manipulate natural predator-prey dynamics, and associated natural ecological processes for the purpose of increasing harvest of ungulates by man; (2) to adversely impact public safety; or (3) to be inconsistent with federal law authorizing sport hunting in national preserves in Alaska.  However, states have primary jurisdiction to manage wildlife throughout their state.  In addition, NPS has broad discretion in managing wildlife on national preserves under applicable laws, policies, and regulations. 

Taking into account the Secretarial Orders described above, NPS has re-considered its earlier conclusions and determined that these previously prohibited practices can be allowed consistent with the goal of aligning its rules with those of the State.  Allowing these practices is consistent with NPS Management Policy 4.4.3 which provides that NPS does not allow activities to reduce the numbers of native species for the purpose of increasing the numbers of harvested species.  The discussion in the 2015 rule of an action’s “intent or potential” to manipulate predator dynamics goes beyond the plain language of section 4.4.3 of Management Policies.  Additionally, the State of Alaska disputes that the hunting methods and seasons (allowed by the state but prohibited by current NPS regulations) are intended to function as a predator control program.  Rather, the State asserts the hunting regulations are intended to provide opportunity for harvests of wolves, coyotes, bears, and other species as requested by the public.  The State also maintains that any effects to the natural abundances, diversities, distributions, densities, age-class distributions, populations, habitats, genetics, and behaviors of wildlife from implementing its regulations are likely negligible.  As noted below, NPS will prepare an environmental assessment for this regulation to determine whether it will have any significant impacts on wildlife or other resources. 

With respect to the practices that NPS previously determined to be inconsistent with federal law authorizing harvest for sport purposes in national preserves in Alaska, no applicable federal law or regulation defines “sport hunting.”  With regard to NPS’s statement in the 2015 rule that baiting poses an increased public safety risk, the State of Alaska’s position is that baiting does not cause bears to become food-conditioned, and therefore a greater safety concern. 

Proposed Rule

For the above stated reasons, the NPS proposes to remove paragraphs (f) and (g) of 36 CFR 13.42.  Paragraph (f) states that State of Alaska management actions or laws or regulations that authorize taking of wildlife are not adopted in park areas if they are related to predator reduction efforts, which is defined as efforts with the intent or potential to alter or manipulate natural predator-prey dynamics and associated natural ecological processes, in order to increase harvest of ungulates by humans.  Paragraph (g) sets forth a table of prohibited methods of taking wildlife for sport purposes in national preserves in Alaska.  Most of these prohibited methods are also prohibited by the State of Alaska.  Some of them, however, conflict with authorizations by the State of Alaska as explained above.  The NPS believes that removing paragraphs (f) and (g) would implement the directive announced in Secretarial Orders 3347 and 3356 by increasing hunting opportunities in national preserves and promoting consistency between federal regulations and state wildlife harvest regulations.  In addition, the proposed rule would remove the definitions of “Big game”, “Cub bear”, “Fur animal”, and “Furbearer” from section 13.1 because those terms are only used in paragraphs (f) and (g). 

Compliance With Other Laws, Executive Orders and Department Policy

Regulatory Planning and Review (Executive Orders 12866 and 13563)

Executive Order 12866 provides that the Office of Information and Regulatory Affairs in the Office of Management and Budget will review all significant rules.  The Office of Information and Regulatory Affairs has determined that this rule is not significant. 

Executive Order 13563 reaffirms the principles of Executive Order 12866 while calling for improvements in the nation’s regulatory system to promote predictability, to reduce uncertainty, and to use the best, most innovative, and least burdensome tools for achieving regulatory ends.  The executive order directs agencies to consider regulatory approaches that reduce burdens and maintain flexibility and freedom of choice for the public where these approaches are relevant, feasible, and consistent with regulatory objectives.  Executive Order 13563 emphasizes further that regulations must be based on the best available science and that the rulemaking process must allow for public participation and an open exchange of ideas.  The NPS has developed this rule in a manner consistent with these requirements. 

This rule is not an E.O. 13771 regulatory action because this rule is not significant under Executive Order 12866. 

Regulatory Flexibility Act

This rule will not have a significant economic effect on a substantial number of small entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq.).  This certification is based on the cost-benefit and regulatory flexibility analyses found in the report entitled “Cost-Benefit and Regulatory Flexibility Analyses: Proposed Revisions to Sport Hunting and Trapping Regulations in National Preserves in Alaska” which can be viewed online at http://parkplanning.nps.gov/akro. 

Small Business Regulatory Enforcement Fairness Act

This rule is not a major rule under 5 U.S.C. 804(2), the Small Business Regulatory Enforcement Fairness Act.  This rule:

(a) Does not have an annual effect on the economy of $100 million or more. 

(b) Will not cause a major increase in costs or prices for consumers, individual industries, federal, state, or local government agencies, or geographic regions. 

(c) Does not have significant adverse effects on competition, employment, investment, productivity, innovation, or the ability of U.S.-based enterprises to compete with foreign-based enterprises. 

Unfunded Mandates Reform Act (2 U.S.C. 1531 et seq.) 

This rule does not impose an unfunded mandate on state, local, or tribal governments or the private sector of more than $100 million per year.  The rule does not have a significant or unique effect on state, local or tribal governments or the private sector.  It addresses public use of national park lands, and imposes no requirements on other agencies or governments.  A statement containing the information required by the Unfunded Mandates Reform Act is not required. 

Takings (Executive Order 12630)

This rule does not effect a taking of private property or otherwise have takings implications under Executive Order 12630.  A takings implication assessment is not required. 

Federalism (Executive Order 13132)

Under the criteria in section 1 of Executive Order 13132, the rule does not have sufficient federalism implications to warrant the preparation of a Federalism summary impact statement.  This proposed rule only affects use of federally-administered lands and waters.  It has no outside effects on other areas.  A Federalism summary impact statement is not required. 

Civil Justice Reform (Executive Order 12988)

This rule complies with the requirements of Executive Order 12988.  This rule:

(a) Meets the criteria of section 3(a) requiring that all regulations be reviewed to eliminate errors and ambiguity and be written to minimize litigation; and

(b) Meets the criteria of section 3(b)(2) requiring that all regulations be written in clear language and contain clear legal standards. 

Consultation With Indian Tribes (Executive Order 13175 and Department Policy)

The Department of the Interior strives to strengthen its government-to government relationship with Indian Tribes through a commitment to consultation with Indian Tribes and recognition of their right to self-governance and tribal sovereignty.  We have evaluated this rule under the criteria in Executive Order 13175 and under the Department’s tribal consultation and Alaska Native Claims Settlement Act (ANCSA) Native Corporation policies and have determined that the rule may have substantial direct effect on federally recognized Indian tribes.  The NPS has invited Alaska native tribes and corporations to consult on the proposed rule and has consulted with those tribes and corporations that have requested consultation. 

Paperwork Reduction Act

This rule does not contain information collection requirements, and a submission to the Office of Management and Budget under the Paperwork Reduction Act is not required.  The NPS may not conduct or sponsor and you are not required to respond to a collection of information unless it displays a currently valid OMB control number. 

National Environmental Policy Act

NPS will prepare an environmental assessment to determine whether this rule will have a significant impact on the quality of the human environment under the National Environmental Policy Act of 1969 (NEPA). 

Effects on the Energy Supply (Executive Order 13211)

This rule is not a significant energy action under the definition in Executive Order 13211.  A Statement of Energy Effects in not required. 

Clarity of This Rule

The NPS is required by Executive Orders 12866 (section 1(b)(12)) and 12988 (section 3(b)(1)(B)), and 13563 (section 1(a)), and by the Presidential Memorandum of June 1, 1998, to write all rules in plain language.  This means that each rule the NPS publishes must:

(a) Be logically organized;

(b) Use the active voice to address readers directly;

(c) Use common, everyday words and clear language rather than jargon;

(d) Be divided into short sections and sentences; and

(e) Use lists and tables wherever possible. 

If you feel that the NPS has not met these requirements, send the NPS comments by one of the methods listed in the ADDRESSES section.  To better help the NPS revise the rule, your comments should be as specific as possible.  For example, you should identify the numbers of the sections or paragraphs that you find unclear, which sections or sentences are too long, the sections where you feel lists or tables would be useful, etc. 

Public Participation

It is the policy of the Department of the Interior, whenever practicable, to afford the public an opportunity to participate in the rulemaking process.  Accordingly, interested persons may submit written comments regarding this proposed rule by one of the methods listed in the ADDRESSES section of this document. 

Public Availability of Comments

Before including your address, phone number, email address, or other personal identifying information in your comment, you should be aware that your entire comment—including your personal identifying information—may be made publicly available at any time.  While you can ask the NPS in your comment to withhold your personal identifying information from public review, the NPS cannot guarantee that it will be able to do so. 

List of Subjects in 36 CFR Part 13

Alaska, National Parks, Reporting and recordkeeping requirements. 

In consideration of the foregoing, the National Park Service proposes to amend 36 CFR part 13 as set forth below:

No, you can’t make up this kind of scat.  The insanity and perversion run so deep that misled, mentally ill people want to protect and live with animals that much of the world once realized are a direct threat to their own existence. 

As a friend and colleague recently wrote: “Somewhere, sometime ago, someone decided that his or her world was missing something and discovered they didn’t have to go afar to find suitable replacements for it; notwithstanding the fact their and our predecessors had worked tirelessly to ensure that the missing something was never to be sought or returned.  Evidently, history is no longer on our side to support centuries of wolf management, practices that worked to ensure that their livestock survival was more important than wolf survival.  Back then the peasantry did not eat wolves, instead they chose to feed on their domestic livestock that were a dependable supply of meat, milk and cheese, the same foods that are so important for most of us today.  Intuition directs me to the most likely source of this apparent need to restore the missing something; it wasn’t a farmer, rancher or even a politician, but a bureaucrat with ecological credentials!” 

And now someone wants to raise money to create a haven to protect a nasty, disease-spreading, wild canine that offers nothing to anyone except the perverse of mind. 

Abstract

It has been posited that coyotes (Canis latrans) in the Northeast eat more deer than those in the Midwest or other parts of the country due to their increased size.  Further, it has also been posited that Northeastern coyotes do not frequently eat small mammals, creating a trophic cascade that increases the incidence of Lyme disease.  However, no one has synthesized the many studies of coyote diets to quantitatively test these hypotheses.  We examined 18 studies of the diet of coyotes from the Northeast and the Midwest and conducted a meta-analysis to test the hypothesis that the diet of coyotes in the Northeast differs from that of coyotes in the Midwest.  Our results show that deer occur significantly more in the diet of Northeastern coyotes than in the diet of Midwestern coyotes, while small mammals occur significantly less.  The occurrence of rabbits, hares, birds, vegetation, and fruit do not differ significantly by region.  This supports the hypothesis that Northeastern coyotes, due to their larger size and hybridization with wolves, are better adapted at hunting large prey.  Although Northeastern coyotes eat fewer small mammals than Midwestern coyotes, small mammals are still a common component of the Northeastern coyote diet.  Thus the abundance of Northeastern coyotes is not likely to be positively correlated to the incidence of Lyme disease.<<<Read More>>>

Jon Lund is the owner and publisher of the Maine Sportsman magazine.  In the March 2018 edition, he asks, “Are Coyotes to Blame for Increase in Ticks?”  His simple explanation is that the presence of an increased population of coyotes in Maine is causing a reduction in the fox population – the trickle-down effect of an increase in ticks, particularly the tick that carries Lyme disease.  The reality is that coyotes compete with and kill, directly and indirectly, the red fox that is sufficiently more adept at killing the small rodents that carry and perpetuate the Deer (Lyme) tick.  In an effort to mitigate what appears to be a festering and growing incidence of Lyme disease in Maine, Lund is wondering if it is time, due to the necessity of a public health risk, to make a more serious effort at reducing the coyote population. 

Maine got along just fine before the coyote took over the countryside and contrary to the many statements made otherwise, we don’t need them. 

However, there is something else I’d like to touch base with readers about that Mr. Lund brings up in his article.  This has to do with the use of chemicals and/or “natural” elements to ward off ticks and insect bites. 

I’m sure that the pharmaceutical industry, and anyone else who stands to make a profit from their drugs to treat Lyme and other diseases, has thoroughly hyped the presence of ticks and instilled ample fear into the masses.  After all, when the people live in fear they will do most anything. 

Lund speaks specifically about permethrin.  Permethrin is a common ingredient found in compounds marketed as insect repellents or killers.  Basically, it attacks the central nervous system of insects. 

Permethrin is a synthetic, or man-made, product derived from pyrethrin. 

Most fact sheets available to the consumer paint the picture of permethrin/pyrethrin as mostly harmless even though long-term effects have not been studied.  Some believe that using products that contain permethrin presents a higher risk of health issues than the odds of getting bit by a tick that will infect you with Lyme or other diseases.  This is something you will have to decide for yourself.  But to make that decision honestly, you should make the effort to understand the presented “remedies” and “threats.”  It’s your health.  Know what you are doing. 

Lund takes the time to explain how ticks are spread around (I don’t find any factual claims that global warming is the culprit) and refers to a study where “…a growing body of evidence suggests that Lyme disease risk may now be more dynamically linked to fluctuations in the abundance of small-mammal hosts that are thought to infect the majority of ticks.” 

The same study tells us that the incidence and presence of Lyme disease are not related to the abundance of deer but to the absence of key small predators. “ We then show that increases in Lyme disease in the northeastern and midwestern United States over the past three decades are frequently uncorrelated with deer abundance and instead coincide with a range-wide decline of a key small-mammal predator, the red fox, likely due to expansion of coyote populations.  Further, across four states we find poor spatial correlation between deer abundance and Lyme disease incidence, but coyote abundance and fox rarity effectively predict the spatial distribution of Lyme disease in New York.  These results suggest that changes in predator communities may have cascading impacts that facilitate the emergence of zoonotic diseases, the vast majority of which rely on hosts that occupy low trophic levels.” 

This claim is in direct contradiction to the theory that predators kill only the sick of the prey species and justifies the “need” for predators to keep our ecosystems healthy.  Not only is there no evidence that the presence of large predators reduces the presence of disease in ecosystems, this study seems to prove the exact opposite. 

We forget or never learned history.  Large predators like wolves and coyotes were not tolerated on the landscape by early settlers.  And there were reasons for that, some of which include not only the destruction of property caused by these critters but it was known that they carried and spread diseases, many of which are harmful and even deadly to humans. 

And yet, today, there is an all-out effort to protect these same predators.  It appears that for some anyway, the demand for an abundance of coyotes at the expense of public health is just fine and dandy.  I don’t see it that way at all and I’m not alone. 

As the trend continues in the direction that it is headed, it should be fairly easy to predict there will be increased fall-out about protecting any animal that spreads dangerous diseases among the people.  Few tolerate the presence of rats knowing and remembering the unbelievable death and destruction caused by the bubonic plague.  Is there a difference in protecting the health and safety of the public because one culprit is a nasty rat and the other is a nasty wild dog? 

Mr. Lund is correct in asking the question about the role of coyotes in Maine, or anywhere else, where, according to provided data, the coyote is directly affecting the growth, perpetuation and spread of Lyme disease. 

If Maine cannot effectively control the population of coyotes for public health and safety with the current management strategies, then it may be time to look at something more effective. 

It is dishonest by the many who blame hunting and trapping for the decimation and/or extirpation of wolves and coyotes but go out of their way to deny that hunting and trapping of the same animals today have any effect on reducing their population numbers. 

Many decades ago when it was decided by governments that wolves and coyotes were destroying property and spreading diseases, one of the elements employed to rid the landscape of the nasty canines and the diseases they spread was a bounty system.  Any bounty must be attractive enough to draw enough to the plan.  What is the limit in the cost of healthcare? 

Such a suggestion will be vehemently opposed by many, especially those who hate hunting and trapping.  They are wrong that think people like Jon Lund and myself might promote a bounty system for coyotes only for improving deer hunting.  Little do these people know and understand the real conservation of wildlife. 

In the normal world which is being left in the dust, there would be no question as to what is the right thing to do.  Normalcy tells us public health and safety take precedence over animals and the spread of disease.  One has to wonder what the extent of the bubonic plague would have been like if people had known and took real action to get rid of the rats that spread the disease. 

But, we live in a Post-Normal world now where many things are upside-down.  Are we to wait until more and more people get sick and die before we begin to act?  Are we serious about finding a cure to a problem or is there just too much money to be made along with the genocide many promote?