The economic impact of wolf depredation is not addressed in this plan, Between 2000 and 2006 estimated direct losses on one ranch ranged between 1.1% and 18.9% of the calf crop and .3% and 3.1% of the cows, estimated indirect losses were $157 to $338 per animal that is on top of actual loss of the animal. In 2007 on that same ranch suffered a loss of 108.00 per steer in weight loss and an increase of $700 in medication for stress induced illnesses caused by wolves, an increase in labor of $1484 all on top of direct losses of $8585 to $11993 in livestock depredation. (economics of depredation Mexican wolf RITF NMSU) Nothing in the new plan addresses how to mitigate those kinds of losses. FWS has not used best available science in determining whether their current management plan will mitigate depredation, the so called proactive management actions determined as solutions to depredation problems in the current BRWRA have not stopped or mitigated wolf depredation. In fact, most studies indicate that each of the actions, carcass removal, hazing, use of fladry and turbo fladry each have a life span of mitigating depredation for approximately a two week period, hardly conducive to stopping a pack of wolves from destroying a familys livelihood. Perhaps had the FWS done an appropriate full engagement of the public and local governments in the beginning of the NEPA process these issues could have been addressed and actual mitigation could have taken place however, to date there has been no real inclusion of the impacted communities or their governments in the NEPA analysis where the law requires their participation. Full communication to the public of all the components of the proposed actions and alternatives is required by law. Relying on 6-7 year old scoping data is inconsistent with the USFWS policy on compliance with NEPA as is ignoring the need for public input meetings in the affected communities. Simplyb asking the counties to sign an MOU near the end of the NEPA process is not a legitimate way to incorporate coordination with local government into the process. Crystal Runyan Diamond
Posted on: Tue, 19 Nov 2013 20:21:45 +0000
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