March 12, Re: Opposition to SB 245 S1 - the Mule Deer Protection Act. Via gherbert@utah.gov. Dear Governor Herbert,

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1 March 12, 2012 Re: Opposition to SB 245 S1 - the Mule Deer Protection Act Via gherbert@utah.gov Dear Governor Herbert, On behalf of our Utah supporters and the undersigned non- profit wildlife conservation organizations, scientists and wildlife biologists, we strongly oppose SB 245 S1, the Mule Deer Protection Act and urge you to veto this bill. This bill allocates $750,000 Utah tax dollars, every year in perpetuity to provide a de facto bounty for the killing of coyotes. We oppose this bill on economic, ecological and ethical grounds as described below. The bill is economically unsound. At a time when state budgets are being cut and Utah taxpayers are feeling an economic crunch, spending limited taxpayer money ($7.5 million in 10 years) on a wasteful and ineffective coyote- killing program is economically unjust to Utah citizens. For this reason alone, SB 245 S1 should be opposed. Most of the funds would come from Utah s general fund, which, according to the Utah State Auditor s Office, represents the main operating fund for the State of Utah. This money would be far better spent to improve our public education system or any number of other worthy causes. The bill is ecologically misguided. Sponsors of SB 245 S1 maintain that the bill is necessary to boost mule deer populations. However, recent research has shown that even spatially and temporally targeted removal of coyotes does not boost the size of deer herds or prevent livestock depredation. Coyotes primarily prey upon rodents and rabbits that compete with deer and domestic livestock for forage. Coyotes are not an important mule deer predator, but their predation on small mammals such as mice may actually create indirect benefits to mule deer. A recent multi- year study in southeast Idaho that involved the targeted removal of coyotes found that the effect of coyote removal on population growth rate [of mule deer herds] was undetectable. 1 Most state and federal wildlife agencies maintain that coyote killing programs are at best ineffective at reducing coyote populations, and are often counterproductive. Removal of coyotes results in more food being available, which in a very short time results in more coyotes demanding yet more food. It is for this reason that the U.S. Department of Agriculture stopped bounty programs decades ago and now publicly denounces them as ineffective. Additionally, one state wildlife management director even called bounties legalized fraud because it is impossible to know where the animals actually came from. They might have been killed out of state. 1 HURLEY, M. A. et al Demographic Response of Mule Deer to Experimental Reduction of Coyotes and Mountain Lions in Southeastern Idaho. Wildlife Monographs 178:1 33; 2011; DOI: /wmon.4. 1

2 A study of a previous coyote bounty program in Utah in 2000 showed no benefit. It found instead that, Overall, these results suggest that while Utah's coyote bounty may provide an enhanced, subsidized recreation program for a small segment of Utah citizens, it is unlikely to have any beneficial effect on populations of livestock or big game. 2 Additionally, most livestock losses are due to disease, birthing complications, and weather. 3 Moreover, killing coyotes can inflict ecological havoc on ecosystems. Fewer coyotes in an area result in more mesocarnivores (e.g. foxes, raccoons and skunks), which eat ground- nesting bird eggs. Therefore, fewer coyotes result in fewer birds, both in total number and in the number of species. 4 Sage grouse, a species that Utah is desperately trying to conserve, are among the imperiled species that may be negatively affected by this. Fewer coyotes can also result in increased rodent populations, some of which carry diseases such as the deadly hantavirus. The bill is ethically indefensible. Historically, coyotes have been shot, snared, trapped, bludgeoned, gassed, and poisoned in the most inhumane ways imaginable. Killing coyotes and offering a reward for scalped ears or other body parts is ethically reprehensible. Further, public surveys show that most Americans oppose the use of taxpayers dollars to indiscriminately kill predators. Sponsors of SB 245 S1 falsely label this bill the Mule Deer Protection Act when it should more accurately be called the Coyote Scapegoat Act. As acknowledged by Utah Division of Wildlife Resources biologists, deer declines in Northern Utah are largely attributable to harsh winters and habitat loss. Please ensure that sound economics and science guide wildlife management in Utah by vetoing SB 245 S1. This will best serve the citizens of Utah. Thank you for your consideration of our comments. Respectfully submitted, Camilla H. Fox, Project Coyote Wildlife Consultant, Animal Welfare Institute Kirk Robinson Western Wildlife Conservancy Downington Ave., Salt Lake City, Utah Wendy Keefover Director, Carnivore Protection Program WildEarth Guardians 2 BARTEL, R. A. and BRUNSON, M. W Utah Bounty Participant Behavior. Wildlife Society Bulletin, Vol. 31, N o. 3 (Autumn, 2003), pp U.S. Department of Agriculture - National Agricultural Statistics Service Cattle Death Loss. See also: 4 CROOKS, K. R., AND M. E. SOULÉ Mesopredator Release and Avifaunal Extinctions in a Fragmented System. Nature 400:

3 cc: Alan Matheson, Senior Environmental Advisor to Governor Gary Herbert And on behalf of: Marc Bekoff, PhD Professor Emeritus, University of Colorado, Boulder Boulder, CO Peter Coyote President, Wild Dog Productions, Inc. Mill Valley, CA Chris Darimont, PhD NSERC Postdoctoral Fellow Raincoast Conservation Foundation University of California, Santa Cruz, CA Jim and Jamie Dutcher Founders Living with Wolves Sun Valley, ID Garrick Dutcher Program Director Living with Wolves Sun Valley, ID Brooks Fahy Executive, Director Predator Defense Eugene, OR Michael W. Fox, D.Sc., PhD., B.Vet.Med., M.R.C.V.S. Veterinarian, Bioethicist and syndicated columnist Minneapolis, MN Jennifer Hillman Western Regional Director, Seattle, WA The Humane Society of the United States Washington, DC Buz Marthaler Chairman, Board of Directors Wildlife Rehabilitation Center of Northern Utah Ogden, UT 3

4 Dan Miller Bear River Watershed Council Richmond, UT Eric Mills Coordinator Action for Animals Oakland, CA Michael P. Nelson, PhD Associate Professor of Environmental Ethics Lyman Briggs College, Department of Fisheries and Wildlife, and Department of Philosophy Michigan State University East Lansing, MI Paul Paquet, PhD Senior Scientist Carnivore Specialist, Raincoast Conservation Foundation Meacham, Saskatchewan David R. Parsons, MS Wildlife Biologist Project Coyote - Science Advisor Albuquerque, NM Walter L. Pepperman ll, BS and LLB Attorney, Wildlife Advocate and Vice President The Maine Wolf Coalition, Inc. Middletown Springs, VT Richard P. Reading, Ph.D. Associate Research Professor University of Denver Denver, CO D.J. Schubert Wildlife Biologist Animal Welfare Institute Washington, DC Debbie Souza- Pappas Director Second Chance Wildlife Rehabilitation Price, UT Michael Soulé, PhD Professor Emeritus, Environmental Studies, University of California, Santa Cruz Past President and co- founder, Society for Conservation Biology 4

5 Paonia, CO John Toppenberg, Director Alaska Wildlife Alliance Anchorage, AK Geri Vistein, MS Carnivore Conservation Biologist Washington, ME Jonathan Way, PhD Eastern Coyote Research Osterville, MA Amaroq Weiss, MS, JD Advisory Board Member California Wolf Center Petaluma, CA Steve Wells Animal Legal Defense Fund Cotati, CA Jennifer Wolch, PhD William W. Wurster Dean, College of Environmental Design Professor of City & Regional Planning University of California, Berkeley Berkeley, CA 5