*Letter also sent to Attorneys General in Texas and Wyoming

October 1, 2007

Attorney General Drew Edmondson

313 NE 21st Street
Oklahoma City, OK 73105
Phone: 405.521.3921
Fax: 405-522-0085
Email via: trevor.hammons@oag.ok.gov
Re: Killing Coyote Pups At their Dens

Dear Attorney General Edmondson:
We, the undersigned organizations, hereby request that your office investigate the employees of the U.S. Department of Agriculture-Animal and Plant Health Inspection Service-Wildlife Services (“Wildlife Services”) to determine whether agency staff  may have violated state cruelty to animals laws during the course of their canid “denning” activities. “Denning” is a management practice in which coyotes and foxes are killed at or in their dens. Wildlife Services conducts “denning” operations in Oklahoma.
We have long opposed denning of young animals and are stunned to learn Wildlife Services’ agents may be using shovels or other hand tools to decapitate coyote pups or their bare hands to perform “cervical dislocation”[1] – breaking the pups’ necks. We believed these grisly practices had died out decades ago after Congress held oversight hearings in the 1960s and ‘70s of the agency now known as Wildlife Services.[2] Tragically, we discovered they may still be used. The matter came to light when the undersigned researched what the agency meant by “hand tools,” as reported in Wildlife Services’ 2006 kill tables – tables it releases annually.[3]
A Wildlife Services’ employee indicated that agency personnel used “shovels to cut the heads off coyote pups” or to “crush their skulls.” [4] In another communication, a Wildlife Services biologist stated the agency “dispatches coyote pups either by shotgun blast or cervical dislocation.” He described cervical dislocation as “twisting the head of a coyote pup until their neck broke, just like you do to a chicken.”[5] Furthermore, Wildlife Services spokeswoman, Teresa Howes, tacitly acknowledged these horrific acts with hand tools were being carried out. She told the Associated Press, “she would not be shocked” if the agency was using shovels to behead coyotes.[6]
Wildlife Services also uses “large gas cartridges,” which agents bury in dens, to asphyxiate pups with carbon monoxide. [7] The Environmental Protection Agency’s label for the cartridges states, “this cartridge will burn vigorously until completely spent and is capable of causing severe burns to exposed skin and clothes, and of igniting dry grass, leaves, and other combustible materials.”[8] There is a very real possibility pups and other wildlife are being burned alive when buried with these devices.  

Given these troubling revelations, we have asked the agency to cease denning activities and to audit its staff. In addition, we have urged Wildlife Services to abandon its historically aggressive lethal control campaign against coyotes and instead employ non-lethal methods aimed at preventing conflicts with the animals. Finally, we respectfully request a meeting with you to discuss these critical and disturbing issues. To arrange a meeting with our organizations, please contact Brian Vincent or Spencer Lennard, Big Wildlife, at big_wildlife@shaw.ca or 541-846-1352. Thank you. 

Sincerely yours, 

Brian Vincent, Communications Director
Big Wildlife
PO Box 489
Williams, OR 97544
Phone: 604-618-1030; 541-846-1352
Email: big_wildlife@shaw.ca
Web: http://www.bigwildlife.org

On behalf of:
Wendy Keefover-Ring, Director
Carnivore Protection Program

911-11th Street, Ste. 103

Boulder, CO 80302

Phone: 303-447-8655, Ext. 1#

Email: wendy@sinapu.org

Web: http://www.goagro.org/

Web: http://www.sinapu.org/


Stephanie Boyles, M.S., Wildlife Biologist
Domestic Animal and Wildlife Rescue & Information Department
People for the Ethical Treatment of Animals (PETA)
501 Front Street
Norfolk, Virginia 23510
Web: www.helpingwildlife.com
Michael Robinson, Conservation Advocate
Center for Biological Diversity
P.O. Box 53166
Pinos Altos, NM 
Web: www.biologicaldiversity.org 

Melissa Gonzalez, National Campaigns Coordinator
In Defense of Animals
3010 Kerner Boulevard
San Rafael, CA 94901
Web: http://idausa.org/
Nicole G. Paquette, Esq.
Director of Legal and Government Affairs &
General Counsel
Animal Protection Institute
1122 S Street
Sacramento, CA 95814
Web: www.api4animals.org 

Elizabeth Walsh, Chair
Wildlife and Endangered Species Committee
Sierra Club
7717 Waterhouse Dr.
El Paso, TX 79912
Web: http://sierraclub.org/
Marc Bekoff, Professor of Biology
296 Canyonside Drive
Boulder, CO 80302
Web: http://literati.net/Bekoff
Web: http://www.ethologicalethics.org

D.J. Schubert
Animal Welfare Institute
P.O. Box 3650
Washington, DC  20027
Web: www.awionline.org

Karen Michael
Animal Defense League of Arizona
PO Box 43026
Tucson, AZ 85733
Web: http://www.adlaz.org
Melissa Hailey, Esq.
Grazing Reform Program Director

Forest Guardians

312 Montezuma Avenue, Suite A

Santa Fe, NM 87501

Web: www.fguardians.org

Elisabeth Jennings, Executive Director

Animal Protection of New Mexico, Inc.

P.O. Box 11395

Albuquerque, NM 87192

Web: http://apnm.org/

Kirk Robinson, Ph.D, Executive Director
Western Wildlife Conservancy
68 South Main St., Suite 4
Salt Lake City, UT 84101
Web: http://www.westwildcon.org/
Anja Heister
Footloose Montana
2120 Hummingbird Dr., Missoula, MT 59808
Web: http://www.footloosemontana.org/
Sharon Seneczko, President
Black Hills Mountain Lion Foundation
12478 Hwy 16A
Custer, SD 57730
Web: http://www.blackhillslions.com/ 

Tom Hunerkoch, DVM
Mountain Cats Trust
21315 Englewood Road
Lead, SD 57754

Bill Beaudin, Owner
Six Shooters of Colorado
8485 Red Spring Valley Rd.
Colorado Springs, CO
United States Congress Members:
Senator Tom Harkin
Senator Patrick Leahy
Senator Barbara Boxer
Representative Peter DeFazio
Representative Rosa DeLauro

[1] The American Veterinary Medical Association (AVMA) states cervical dislocation is used “to euthanatize poultry, other small birds, mice, and immature rats and rabbits.”[AVMA Guidelines on Euthanasia, June 2007.] Dr. Robert Hilsenroth, Executive Director for the American Association of Zoo Veterinarians, noted AVMA guidelines require that, prior to performing cervical dislocation, the animal be anesthetized and weigh less than 1 kg. In his professional judgment the AVMA guidelines would not apply to coyote pups. (Personal communication, Brian Vincent of Big Wildlife and Dr. Hilsenroth (September 11, 2007.))

[2] The federal agency charged with killing wildlife for the benefit of the livestock industry, and others has had several names in the last century including “Animal Damage Control”, “Predatory Animal and Rodent Control”, and the “Biological Survey.”

[3] Table G, FY2006, <http://www.aphis.usda.gov/wildlife_damage/prog_data_report_FY2006.shtml>.

[4] Personal communication, Brian Vincent of Big Wildlife and employee of Oklahoma Wildlife Services, (September 11, 2007). See also, Associated Press, “Group Decries Killing of Coyote Pups,” <http://www.examiner-enterprise.com/articles/2007/09/13/news/state/news080.txt>, September 12, 2007.

[5] Personal communication, Brian Vincent of Big Wildlife and employee of Texas Wildlife Services, (September 24, 2007).

[6] Associated Press (supra).

[7] EPA Registration Number: 56228-21 (April 1996).  Large gas cartridges, used for asphyxiating coyotes, red foxes, and striped skunks is comprised of a mixture of sodium nitrate (53%), Charcoal (29%), and Inert Ingredients (19%).

[8] Ibid.