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A hunters' rights organization has formally requested a federal permit to hold a multi-year predator-killing derby in Idaho — on national public lands!
If approved this will be the second competitive wolf-killing competition held in Idaho - and no predator will be safe!
If you think it can't get worse, consider this: The proposed event would take place every winter for five years when wolves and other wildlife are most vulnerable out foraging for food in the snow and extreme cold.
Please stand with us, and call on the BLM to immediately deny this outrageous request!
Dear Ms. Townley,
I am adamantly opposed to the request from Idaho for Wildlife to host a multi-year, commercial derby-style hunt for wolves and other predators on more than 3 million acres of Bureau of Land Management (BLM) public lands in Idaho, including 17 areas specially managed to preserve their wilderness character. This event would be damaging to the affected ecosystem, harmful to threatened and sensitive species, incompatible with modern day scientific principles for public lands and wildlife management, and offensive to the concept of fair chase. I strongly urge you to deny this request for a special use permit to a hold a multi-year predator derby on public lands in Idaho. At the very least, this permit request demands a full Environmental Impact Statement (EIS). The proposed action area is vast, covering a matrix of land types inhabited by several sensitive and threatened species and is proposed to recur annually for five years. These attributes require full and thorough evaluation through the preparation of an EIS.
The proposed derby would continue the violent persecution of wolves in Idaho. Repeated, concentrated targeting of wolves led to the species' extirpation in Idaho historically and could contribute to serious declines in the species again. As a BLM-designated sensitive species, the agency must analyze how the proposed derby will affect its responsibility to sustain wolf populations on BLM lands. Federal taxpayers spent millions of dollars returning this important apex predator back on the landscape, and this event would recklessly undermine that investment.
Further, with up to 500 participants "hunting for as many predators as they are able to harvest within 3 days," the derby is also likely to put other sensitive species at risk. Participants could misidentify their targets and kill wolverines, fishers, kit foxes or Canada lynx, a threatened species listed under the Endangered Species Act (ESA). The mass removal of skunks, weasels, jackrabbits and other "predatory" animals could also reduce the prey base for a suite of native carnivores at a time of year when food is scarce.
Proponents of the derby are seeking to repeat the same 3-day event on the same public lands for 5 consecutive years. A chronic, repeated short-term use such as this does not meet the definition of "temporary" under the non-impairment standard for managing wilderness-quality lands. Further, there is a reasonable expectation that this proposed derby will "create a demand for uses that would be incompatible with wilderness management" that do not meet the definition of temporary under this standard. The BLM is required to manage these Wilderness Study Areas "to preserve wilderness characteristics so as not to impair [their] suitability...for designation by Congress as wilderness." Intrusive, unrestrained commercial uses such as predator-killing derbies are an anathema to this objective.
Many hunters have argued that the so-called North American Model of Wildlife Conservation should guide decisions with respect to hunting on BLM-managed lands. This predator derby permit request is clearly inconsistent with the fourth tenet of that model, that Wildlife Should Only be Killed for a Legitimate Purpose. This derby is an inappropriate and unethical commercial contest, set apart from sport hunting or hunting for subsistence. The "Winners" of the derby will receive a financial prize for their take, thus commercializing the taking of these predators, the very antithesis of a "legitimate purpose."
Finally, I urge you to deny this request on the grounds that it is a gross misuse of our public lands. Predator derbies are a 19th century practice that played a significant role in driving species to extirpation, creating the need for the ESA and the reintroduction and continued conservation of many predator species in North America. Hunting in winter, when species can be easily tracked in snow and when most animals are working hard to survive, is also offensive to the tradition of fair chase. The BLM should not condone such activities on the public domain.
Thank you for your consideration.