October 9, 2007

William Clay, Deputy Administrator
U.S. Department of Agriculture-APHIS-Wildlife Services
14th and Independence Avenue, SW, Room 162 South
Washington, D.C. 20250-3402
Phone: 202-720-2054
Fax: 202.690.0053
Email: bill.clay@aphis.usda.gov
Re: Request to Wildlife Services to Halt Killing of Canid Pups At their Dens

Dear Deputy Administrator Clay:
We, the undersigned organizations, urge the U.S. Department of Agriculture-Animal and Plant Health Inspection Service-Wildlife Services (“Wildlife Services”) to halt the killing of canid pups at their den. Usually this practice involves coyotes and foxes and is commonly referred to as “denning.”
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] – that is, 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. 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 the 2006 kill tables.[2]

A Wildlife Services’ employee indicated in one phone call that agency personnel used “shovels to cut the heads off coyote pups” or to “crush their skulls.” [3] In another, an agency biologist stated employees “dispatch 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.”[4] 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.[5]

Wildlife Services also uses “large gas cartridges,” which agents bury in dens, to asphyxiate pups with carbon monoxide. [6] 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.”[7] There is a very real possibility pups and other wildlife are being burned alive when buried with these devices.  

Given these troubling revelations, we ask the agency to cease any future denning activities and to audit Wildlife Services staff. Any employee engaged in killing pups with shovels or other hand tools or performing cervical dislocation on pups should be prosecuted under cruelty to animals statutes and censured. Finally, we urge 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. 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: 541-846-1352
Email: big_wildlife@shaw.ca
Web: http://www.bigwildlife.org

On behalf of:

Dr. John Grandy, Senior Vice President
Wildlife Department
The Humane Society of the United States
Gaithersburg, MD
Web: http://www.hsus.org
Stephanie Boyles, M.S., Wildlife Biologist
Domestic Animal and Wildlife Rescue & Information Department
People for the Ethical Treatment of Animals (PETA)
Norfolk, Virginia
Web: www.helpingwildlife.com
Michael Robinson, Conservation Advocate
Center for Biological Diversity
Pinos Altos, NM

Web: www.biologicaldiversity.org 

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

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

D.J. Schubert
Animal Welfare Institute
Washington, DC
Web: www.awionline.org

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

Forest Guardians

Santa Fe, NM

Web: www.fguardians.org

Elisabeth Jennings, Executive Director

Animal Protection of New Mexico, Inc.

Albuquerque, NM

Web: http://apnm.org/

Kirk Robinson, Ph.D, Executive Director
Western Wildlife Conservancy
Salt Lake City, UT
Web: http://www.westwildcon.org/
Anja Heister
Footloose Montana
Missoula, MT
Web: http://www.footloosemontana.org/
Sharon Seneczko, President
Black Hills Mountain Lion Foundation
Custer, SD
Web: http://www.blackhillslions.com/ 

Tom Hunerkoch, DVM
Mountain Cats Trust
Lead, SD

Bill Beaudin, Owner
Six Shooters of Colorado
Colorado Springs, CO
Randi Spivak, Executive Director
American Lands Alliance
Washington, DC
Web: http://americanlands.org/

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

[3] 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.

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

[5] Associated Press (supra).

[6] 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%).

[7] Ibid.