Wildlife Services -- Legislative Action

Export Program for Certain Native Species under the Convention on International Trade in Endangered Species of Wild Fauna and Flora

The American Sheep Industry Association (ASI) appreciates the opportunity to comment on the Draft Environmental Assessment: Export Program for Certain Native Species under the Convention on International Trade in Endangered Species of Wild Fauna and Flora. ASI has been the national trade organization representing the interests of nearly 90,000 sheep ranchers located throughout the country who produce America’s lamb and wool since 1865. ASI is a federation of forty-five state sheep associations and individual members representing a diverse industry who have an immense interest in wildlife management issues.

ASI, wishes to express our support for the proposed action under the above referenced rulemaking, the “no action” alternative. It is the position of our membership and affiliates that the U.S. Fish and Wildlife Service (USFWS) has already exceeded their due diligence requirements by its thorough research and documentation of this issue.

We commend USFWS on their work with the States and Tribes over the past 40 years to develop a program that recognizes both the value of sustainable wildlife populations and the importance of hunting and trapping as cost effective wildlife management. Our members believe that it is the responsibility of the States and Tribal authorities to maintain and regulate wildlife populations, adding to the aesthetic value of our landscapes and driving economic progress. Regulations that further erode participation in hunting and trapping hinder wildlife management and are detrimental to wildlife populations and habitat.

We request that USFWS proceed with the proposed action and again thank you for this opportunity to provide input.

Secretary Vilsack's Letter to Wayne Pacelle of The Humane Society of the United States (HSUS) Defending WS
Today's WS delivers a vital service to farmers and ranchers throughout the United States by providing Federal expertise in controlling wildlife that damages valuable animals and crops, enabling these producers to remain profitable, feed consumers here and abroad, and contribute to their communities. In fact, cost-benefit analyses have shown that for each dollar spent on livestock protection, WS saves producers between $2 and $7 in losses. WS also serves the American public as a whole by reducing potentially devastating aviation bird strikes in every State, assisting in the recovery of endangered and threatened species, monitoring wildlife across the country for diseases to help protect animal and human health, and saving wildlife species in emergency response situations." Vilsack

Rebuttal to WS Articles Published in the Sacramento Bee
The Sacramento Bee published a series of articles during the spring of 2012. The articles were published on April 28, 30, and May 7, with an Editorial published May 6 and sidebars, along with an on-line Q&A with the author on May 2. The articles were critical of APHIS Wildlife Services' (WS) policies, practices, and staff. Specifically, the series of articles charged that APHIS WS methods for controlling predator populations are outdated and that APHIS staff conducting these operations are not qualified to perform work in that capacity.

June 16, 2011 - Final Vote Results for Roll Call 542 - Campbell/DeFazio Amendment
State-by-State Roll Call
Ayes verus Noes Vote

Rep. Frank Luca's (Okla.) Dear Colleague Letter Opposing Campbell/DeFazio Amendment

Predator management is a constant and critical part of sheep production across the United States. Without active management, predators will "eat the sheep farmer out of operation."

There is no question that coyotes are the dominant predator to conflict with livestock production in the United States, particularly sheep and especially lambs. Coyotes are so numerous that states typically have no season nor limit on harvest from hunting. Trapping generally involves a season outside of the wildlife regulations allowing coyotes to be taken as a pest or danger to transportation, health or property damage.

Coyotes kill for a living. There is no magical way to train a coyote to not like the wonderful taste and tenderness of lamb.

While hunters and sportsmen harvest far more coyotes nationwide than the predator control program, effective predator control is not about taking predators but rather about the timing of protection of livestock. Predator control is most critical in the spring, for example, while the ewes are giving birth and nursing young lambs. This, however, is opposite the time of year when sportsmen are interested in hunting coyotes for fur.

Animal rights advocates criticize the professional wildlife managers of state, county and federal government as well as the private landowners for programs designed to mitigate the damage caused to agriculture by publicly owned wildlife.

The sheep industry actively supports wildlife damage management because it is absolutely crucial to protect our animals from the wasteful death and injury caused by predators. Secondly, sheep producers, like cattle producers, are among the largest private landowners in America and provide a tremendous portion of the total habitat for wildlife in this country. Therefore, managing the damage and conflict from the public owned wildlife on our land (leased or owned) and livestock is a continual balance of land stewardship and animal health.

Agriculture landowners, county and state governments and sportsmen support professional wildlife management. This management frequently means finding solutions to conflicts; yet animal rights activists argue that the federal government should have no role in wildlife damage control. They argue against management tools for use in mitigating damage caused by wildlife.

The sheep industry is proud to help feed and clothe the people of America and of the world. In return, it asks for the federal wildlife management to continue to share the responsibility of damage control with state and local government and landowners and operators.

Animal rights advocates criticize the federal role in the control of the Canadian wolves re-introduced into Idaho, Wyoming and Montana. Yet, they fully supported the role the U.S. Fish and Wildlife Service (USFWS) played in mandating the re-introduction of the wolf. In other words, according to the animal rights advocates, it is apparently fine for there to be a federal role (USFWS) to mandate the re-introduction, however, professionals from the USDA Wildlife Services should not be used by USFWS to address the problem animals.

It would be poor public policy for the federal government to not provide professionals to assist with the damage caused by wildlife.

The documents and materials on this Web site are provided to clarify the need for predator management and effective predator control tools.


In 2004, ASI published a special issue of The Sheep & Goat Research Journal focusing entirely on predation. The articles in this issue of the journal address the predation issues found in the sheep industry. All of the articles have been peer reviewed.

SPECIAL ISSUE: PREDATION -- Sheep and Goat Research Journal