Invisible Voices

a voice for the voiceless

Kofa Mountain Lions – formal scoping period

kofa lion, dead

Apologies for starting off with a gruesome photo. Sometimes it is necessary to know what the stakes are. That is a picture of the first Kofa Mountain Lion, killed in September 2007. Picture provided to me by Ron Kearns, who received it from the government through a public records request. This mountain lion (aka cougar aka puma) had killed more than one Bighorn Sheep in a six month period, and that is how the Kofa National Wildlife Refuge managers justified killing him.

I’ve been writing about the Kofa Mountain Lions for almost a year and a half. I stumbled on the first bit of information sort of by chance. I can’t actually remember how I came across the information. At the time, it was during a public comment period about the Mountain Lion proposed hunt. I wrote in, got some friends to write in, and in the end it was HSUS (believe it or not) that saved the day, at least temporarily, for those mountain lions, via a lawsuit against the US Game and Fishing Department.

Since then, two of the five Kofa Mountain Lions have been hunted via radio collar and killed in government sanctioned canned hunts.

The reason given for the killing was that the Bighorn Sheep population was at the lowest level since the 1980’s. Potential causes for population decline would include: drought, disease and sickness, and disturbance and/or destruction of habitat, especially sensitive areas, in addition to whatever impact the mountain lions have on the population. Hunters, who all along have been sold hunting permits for the Bighorn Sheep despite the low sheep population, are never included in the “official” lists of possible causes of lowering sheep numbers. For that, among other reasons, the list I mentioned is not exhaustive. It is safe to say that no one has bothered to find out, yet, exactly why the sheep population has dropped. They simply used it as an excuse to kill mountain lions in radio collar canned hunts.

The government agencies also neglected to mention that the sheep population rose by close to 20% between 2006 and 2007. While all five mountain lions were alive. (The first was killed in September of 2007, so in the interests of accuracy, all five lions were only impacting the populations for 3/4 of 2007, and only four lions for the remaining quarter of 2007.)

So the government mislead the public. The government used partial information to justify killing mountain lions that had killed two sheep in a six month period. The government, however, refused to even limit the number of sheep hunting permits they were selling, even while they claimed the sheep population was in danger due to the predation of the lions.

PEER (Public Employees for Environmental Responsibility) stepped up to the plate this time, and again the mountain lion hunting has been halted, this time for a year. In this next year the government is going to go through the formal analysis process, including a “formal scoping period”, to start research into the impact the mountain lions are having on the sheep populations.

We all know that the government is already biased towards the hunters, against the mountain lions, against biodiversity, against letting animals live their lives for themselves, rather than as entertainment revenue. The hunting permits for the Bighorn Sheep are the refuge’s biggest source of income. We know this, and yet the government is actually obligated to go through this formal process to justify what they are doing.

And this is where we come in. You, and me, and everyone else can write in and give our arguments against the mountain lion hunting.

From now until May 24, 2008 it is what they call the “formal scoping period” and we can send letters, electronically or via snail mail, with our thoughts, and have them entered formally and officially in public record. And, especially importantly, we should include our suggestions for alternatives. For instance, no hunting of mountain lions on Kofa NWR by agencies or hunters.

That would be a really fantastic alternative to propose.

And since this is the government, it isn’t just the logic, the science, and the information that will count, but the number of people who register with that opinion.

It is “just” three mountain lions that we’re fighting for, but it is more than that too. It is the right for animals to live their own lives. We argue for this all the time when we try to convince people to go vegan, and I think most of us sort of assume that the wild animals already have this freedom…freedom to live. Yet, that is far from the truth. The government likes to manage the wildlife just as much as they like to manage everything else. (This should be no surprise: deer, wolves, mute swans, pigeons, canadian geese, coyote, bear, seals, squirrels…just about every animal exists on the sufferance of people in power who make decisions about their lives.)

So it isn’t just mountain lions we’re fighting for, but all animals. How can we argue for “domestic” animals to have freedom if we can’t even guarantee it for wild animals?

Well, we clearly can and need to do both. It isn’t mutually exclusive.

Ron Kearns is the main reason I’ve kept up with everything going on with the Kofa Lions. He worked there for most of his career, he has a lot of contacts in the area, and one of those contacts supplied him with a great chart that shows the process, and the impact that this formal scoping period can have.

nepa decision making chart

It isn’t often that they are required to listen to us. Of course there is a danger as well – our silence, if we stay silent, makes the voices of those who want the death of the mountain lions that much louder. To my mind, the letter writing for the scoping period is both an opportunity and an obligation.

The Fish and Wildlife Service has (finally) posted the pdf explaining the formal scoping period for the Mountain Lions on their website. The press release is also available, and there are additional links on that page that might be helpful to read.

If you want to write but aren’t sure where to start, or have any question on either the process or the science or whatever, please let me know and I’ll do whatever I can to help. You can read other things I’ve written about the Kofa Mountain Lions.

It doesn’t have to be elaborate, but the more letters that the government receives on behalf of the mountain lions, the more impact that point of view will have overall. It is just three mountain lions, you might be thinking, but it is more than that too. It is a chance to make a stand for wildlife, to make a statement that wildlife is no more there for our purposes than any other animal is.

You can visit for additional background information.

Comments must be submitted in writing by May 24, 2008.
SnailMail: U.S. Fish and Wildlife Service, 356 W. 1st St., Yuma, AZ 85364

Some websites to look at for information on cougars (aka mountain lions aka pumas): (“Using Science To Understand Cougar Ecology”)

An article that discusses the importance of predators in maintaining biodiversity, written in readable science: Predator-Prey Relationships

Some issues I think are important to bring up:

  • Biodiversity, and the importance of predators
  • The lack of concrete knowledge of how much a mountain lion will actually eat
  • The negative impact caused by human intrusion on sensitive areas
  • Disease, especially that transmitted from domesticated sheep; this is impacted also by habitat pressure
  • The refuge managers’ refusal to halt bighorn sheep hunting despite the lower-than-normal sheep numbers
  • The refuge managers’ behavior in misleading the public about the current state of the sheep population, which grew by almost 20% from 2006-2007 (according to their own surveys) while all five mountain lions were still alive, and using the only the data from 2001-2006 (during which there was a decrease in sheep populations) to justify killing the mountain lions in late 2007 and early 2008.

Please also mention that you want an alternative to be considered…such as no hunting of mountain lions on Kofa NWR by agencies or hunters.

When it comes time for the other parts of this process, only alternatives presented during this formal scoping period will be considered. If we don’t suggest no hunting of mountain lions, who will?

Thanks to anyone who will write. Thanks to Mary for posting about this a couple days ago, and Ron for making sure I have been kept up to date on everything going on.

Picture of “K03”, killed earlier this month, picture given by the refuge officials to Daniel Patterson.

kofa lion, alive


16 responses to “Kofa Mountain Lions – formal scoping period

  1. Mary Martin April 29, 2008 at 8:23 pm

    I sent in my comment, and I hope others do the same. We claim to be interested in freedom and respect of individuals, and though only a handful of mountain lions are involved, their lives are as important to them as ours are to us. We owe it to them to fight for them.

  2. Ron Kearns April 29, 2008 at 8:37 pm


    Thank you for an outstandingly detailed post. You cataloged the EA process and provided informational links so that others and I can easily follow the steps and find cougar facts to help us make substantive comments during the first-step of public scoping.

  3. Deb April 29, 2008 at 8:51 pm

    Mary, I saw that on your blog, and thank you so much for writing in! I think when it comes to activism of this sort, the “10 billion animals killed for food every year” is so overwhelming that spending some time to write a letter on behalf of just three individuals could seem pointless. Yet I volunteer at a sanctuary every week, and I see first hand just what an impact it is to save the life of even one animal.

    Ron, I’m glad it is helpful! Thanks again for all your help in keeping me up to date on the process and the goings on!

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  5. Ron Kearns May 7, 2008 at 5:12 pm

    How to Comment During Scoping and the draft EA (from a Citizen’s Guide to the National Environmental Policy Act (NEPA)

    This document presents all the detailed NEPA processes:

    Important excerpts:

    Comments that contribute to developing alternatives that address the purpose and need for the action are also effective.

    They are particularly helpful early in the NEPA process and should be made, if at all possible, during scoping, to ensure that reasonable alternatives can be analyzed and considered early in the process.

    How to Comment:

    Comments may be the most important contribution from citizens. Accordingly, comments should be clear, concise, and relevant to the analysis of the proposed action. Take the time to organize thoughts and edit the document submitted. As a general rule, the tone of the comments should be polite and respectful. Those reviewing comments are public servants tasked with a job, and they deserve the same respect and professional treatment that you and other citizens expect in return.

    Comments that are solution oriented and provide specific examples will be more effective han those that simply oppose the proposed project. Comments that contribute to developing alternatives that address the purpose and need for the action are also effective. They are particularly helpful early in the NEPA process and should be made, if at all possible, during scoping, to ensure that reasonable alternatives can be analyzed and considered early in the process. In drafting comments, try to focus on the purpose and need of the proposed action, the proposed alternatives, the assessment of the environmental impacts of those alternatives, and the proposed mitigation. It also helps to be aware of what other types of issues the decisionmaker is considering in relationship to the proposed action.

    Commenting is not a form of “voting” on an alternative. The number of negative comments an agency receives does not prevent an action from moving forward. Numerous comments that repeat the same basic message of support or opposition will typically be responded to collectively. In addition, general comments that state an action will have “significant environmental effects” will not help an agency make a better decision unless the relevant causes and environmental effects are explained. Finally, remember that decisionmakers also receive other information and data such as operational and technical information related to implementing an action that they will have to consider when making a final decision.

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  8. Ron Kearns May 22, 2008 at 7:35 pm

    Good news! The extension of the public scoping period for an additional 30 days, to end on June 23rd of 2008.

    “Subsequently, in response to requests from the public for additional time to identify issues they would like addressed in our planning process, the U.S. Fish and Wildlife Service is extending the public scoping period an additional 30 days, to end on June 23rd of 2008.”

    “As a reminder, comments to be entered into the record must be submitted in writing to our email address at or our mailing address at 356 West 1st Street, Yuma, AZ 85364. To see the original notice, or for additional detailed information, please visit our website at: You may also contact our office directly at (928)783-7861. Thank you.”

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  10. Betty December 16, 2008 at 7:38 am

    Just how stupid are the fish and game dep. these day lions only kill the old the sick the hurt and the very young if they can. Man kill only the best they can find. so boys I may not have a PHD but I know my lions so the cat got two sheep big deal how many permits were issued to kill the very best of the breeding herd cut your issue of permits in half or not at all until the sheep recover end of problem. but I realise that like all goverment agency they are IDIOTS and should be sweeping floors instead of protecting wild life.

  11. Deb December 16, 2008 at 11:13 pm

    Betty, the fish and game departments are hand in hand with the local hunting groups, who care only about being about to go about and kill things, with no regard to ecosystems, sustainability, etc. It’s the same story with the FDA, and the lobbyists on the hill…it always comes down to money. The gov’t is largely sold to the highest bidder.

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  13. DZ September 16, 2009 at 7:40 pm

    You idiots. The lion was killing *endangered* bighorn sheep. What you have the game department do, yell “Bad kitty!”?

  14. Deb September 16, 2009 at 7:53 pm

    The bighorn sheep are not endangered, and hunters have killed FAR more sheep than the lions have. So now who’s the idiot?

  15. Ron Kearns September 18, 2009 at 3:55 pm


    Deb is correct. The bighorn herd within Kofa NWR and the surrounding area, designated as the Kofa Mountains Complex by the AGFD, is *not* an endangered population.

    I understand why you and others would believe that Kofa bighorn are endangered, while that is incorrect, because the AGFD–in public meeting and in official documents–compares Kofa bighorn with other known endangered bighorn populations as a setup tactic.

    The scenario goes; if we don’t kill lions and build artificial waters now on Kofa and environs, our sheep are going to end up like those bighorn herds in the Sierra Nevada and Peninsular regions of California and the costs of recovering those herds is $95 million for just 10 years or so.


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