19981021 Comments on the Use of Compound 1080 Poison in Idaho
7/9/2001, The Fund for Animals

Mr. Patrick A. Takasugi, Director
Idaho Department of Agriculture
P.O. Box 790
Boise, ID 83701-0790

Re: Docket No. 02-0303-9802

Dear Mr. Takasugi:

On behalf of the nationwide membership of The Fund for Animals, including those members and supporters who reside in the state of Idaho, I am submitting the following comments on the Idaho Department of Agriculture's (IDA) proposal to amend the current Rules Governing Pesticide Use and Application to add the Livestock Protection Collar (LPC) containing Compound 1080 as a license category and to allow the United States Department of Agriculture's Wildlife Services (WS) personnel to be licensed to use the LPC.

The Fund for Animals is opposed to the proposed rules. The following specific points outline some, but not all, of our principal objections:

Compound 1080 (sodium fluroacetate) is a highly toxic and slow-acting poison for which there is no antidote. Each LPC contains enough poison to kill up to six healthy adults. It is virtually tasteless and odorless, making its presence extremely difficult to detect. Despite assurances to the contrary, there is a high risk of secondary poisoning to non-target species. The U.S. Fish and Wildlife Service found that 1080 "possesses a high degree of secondary hazard. A single mouse killed with the water solution may contain enough poison to kill a full grown dog." Not only is 1080 lethally toxic, but it persists in the environment, posing a threat for scavengers, companion animals, threatened and endangered species, and humans.

Reducing the risk of secondary poisoning requires adherence to strict regulations for disposal of LPCs and contaminated vegetation, soil and other materials, including recovery of coyote carcasses. Because Compound 1080 is a slow-acting poison, many coyotes will travel substantial distances before succumbing to the poison. In fact, according to Denver Wildlife Research Center studies, only about 10% of the attacking coyotes are recovered after they die. Couple this with missing collars and punctured collars from contact with vegetation, barbed wire and other objects, and there is serious cause for concern about 1080 leaking into the environment. This poses a serious and unnecessary risk to public health, especially given that there is no antidote for the poison and that it is extremely difficult to detect even under laboratory conditions. Requiring immediate reporting of suspected poisoning of non-target species and humans and domestic animals does little good for the victims of secondary poisoning.

Compound 1080 causes a slow and painful death to coyotes. Death may result from cardiac failure, progressive failure of the central nervous system, or respiratory arrest following severe prolonged convulsions and take up to 10 hours to occur. While some ranchers may not be concerned about the pain and suffering of an animal they perceive to be nothing more than a varmint, the vast majority of people are very concerned about the humane treatment of all animals and will be outraged to learn that such a cruel killing method is sanctioned by the IDA.

Given that there is a wealth of scientific support for the position that lethal coyote control in general may actually exacerbate predation problems rather than reduce them, it is difficult to fathom why the IDA would consider the use of such a dangerous toxin especially when nonlethal methodologies (viz., better animal husbandry practices, habitat modification, guarding animals, multi-species stocking, electric fencing, and animal behavior modification through aversive stimuli) have proven to be far more effective in the long term for controlling predation problems. And, while the proposed rule calls for the LPC to be used only as a "last resort," it is unclear how this determination will be made.

In addition, it is especially troubling that the IDA has designated WS personnel as the registrant for LPC use in the state. According to a report issued by the Government Accounting Office in 1990, "Little evidence exists of state Animal Damage Control program personnel employing such [non-lethal] methods. Rather, killing offending animals is used predominantly to control predation on livestock." Another report in October of 1995 expressed the same concern. Although WS' program's written policy states field personnel should give preference to non-lethal methods whenever practical and effective, in fact, they use lethal methods in essentially all instances. We fear that WS will merely see the LPC as yet another weapon to use in its lethal arsenal to control predators. If WS isn't following its own policies and directives about using nonlethal methods of control, why should we believe that agency personnel will adhere to state rules? I trust we need not remind the IDA of the problems associated with monitoring and enforcing regulatory compliance.

Moreover, last week, I spoke with an Environmental Protection Agency official in Washington, D.C. who is responsible for disseminating information about Compound 1080. In his opinion, it would not be advisable to use Compound 1080 in conjunction with the presence of guarding dogs due to the possibility of their accidentally ingesting the poison if a collar was punctured. So the question presents itself: will ranchers be required to use guarding dogs and exhaust other nonlethal methods of predator control or not? The proposed rules offer no explanation for what is meant by "last resort." Furthermore, it is simply unclear how many producers actually utilize nonlethal methods of predator control and which of those methods are in use at any given point in time.

WS spends more money to control predators than livestock producers report being lost to predators. Undeniably, coyotes do kill livestock. But it is questionable whether they predate on livestock at the levels purported by the industry. Simply because coyote tracks or signs are seen near a sheep carcass does not mean the animal was killed by a coyote. Many researchers believe that livestock and wild ungulates are represented in coyote stomachs and scats as carrion rather than taken as live prey. Since coyotes consume livestock as carrion, it doesn't necessarily follow that all livestock deaths were the result of coyote predation. In fact, in Idaho in 1995, the most significant reported loss of sheep and lambs resulted from natural causes such as disease, old age, climatic conditions, starvation and dehydration, fire, and poisoning. While it was alleged coyotes were accountable for approximately 25 % of deaths of sheep and lambs in 1995, that figure in all probability is inaccurate due to these false assumptions.

Finally, the level of risk associated with use of Compound 1080 is simply too high. It would be irresponsible and reckless for a governmental agency to place the public and non-target wildlife at risk for the relatively few, if any, benefits associated with its use for a small number of ranchers. As we move into the 21st century, it is time to embrace progressive approaches to resolve wildlife/human conflicts rather than to repeat the mistakes of the past. For these and other reasons, The Fund for Animals urges the IDA to reject the proposed rules allowing for the use of Compound 1080 in LPCs.

Thank you for the opportunity to submit these comments. If you have any questions, please feel free to contact me at (307) 859-8840.

Sincerely,

Andrea Lococo
Rocky Mountain Coordinator