Invisible Voices

a voice for the voiceless

My letter for the Kofa NWR Lion formal scoping period

My recommendation for the management of the Mountain Lions on Kofa National Wildlife Refuge is: no hunting of mountain lions on Kofa NWR by agencies or hunters. My reasons are as follows:

1. Bighorn Sheep herds on Kofa NWR have increased in size by a significant number (from 390 to 460), around 17%, from 2006-2007. This eliminates the main justification presented for killing the mountain lions. The herd increased in size while a minimum of four of the original five mountain lions were alive, to state it conservatively. The first lion was killed in June of 2007, and it is reasonable to make an assumption that the herd was increasing even in the first six months of 2007, while all five lions were alive. At the very least, the herd increased substantially while four lions were alive. There are now a maximum of three lions on the refuge, since a second mountain lion was killed in April of 2008, so the justification for killing more lions are further weakened.

2. There has been no research done to determine how much a mountain lion can be expected to eat. The limit of “2 sheep in a six month period” are arbitrary and ignorant, and thus unethical as a basis of life or death decisions being made for the animals within the protection of the refuge managers, the AGFD and the USGFD.

3. It is a basic fact of population biology that predator populations are self-limited by the prey population sizes. In other words, the mountain lions are not going to hunt the Sheep into a permanent decline – it is only humans who so completely disregard the natural laws of the world around them. Mountain Lions have strong territorial drives, and that further limits the total number of lions that would reside in any given area. The mountain lions are not endangering the sheep herds.

4. There has been no data gathered to support the theory that the Sheep population size can be expected to maintain a constant size even during decade long droughts. Kofa NWR is situated in an area that has been suffering a severe drought for over a decade. Again, the most basic population biology informs us that the herd size will naturally decrease in conjunction with the decreasing resources expected in a drought situation. Therefore it is is unreasonable both to expect the herd size to maintain pre-drought numbers, as well as to then blame the mountain lions for the decrease in sheep numbers.

5. Research Biologist Ted McKinney questioned statements that lion predation can have significant population level impacts, referring to the top experts on the subject when he said: “Note that Sawyer and Lindzey state that NO studies have clearly demonstrated population-level impacts.” Lindzey is well known to be an expert on Mountain Lion biology, and his research should have been studied exhaustively.

6. No data was gathered by Kofa biologists to determine the actual cause of the Bighorn Sheep decline. Sheep are known to be very sensitive to environmental stresses, which include droughts, habitat pressure, and disturbance of sensitive lambing areas. In the 1980’s, Kofa Sheep herds had a dramatic decline due to respiratory ailments, yet no necropsies were done in response to the current decline. That’s illogical. These types of questions need to be resolved in order for any logical plan to be worked out for recovery, if warranted. As it happens, there were at least two environmental stresses that the sheep had to deal with – the drought, as well as the disturbance of their lambing areas, which hunters were given access to.

7. There has been no research to determine the actual impact of hunters and hikers through the sensitive lambing areas. It is known that they do have access to these areas, and that hunters do disturb gravid ewes during hunting season, which causes some (as yet undetermined amount of) lamb mortality. Their impact should be quantified, since it might justify limiting their access to these areas.

8. We are in the middle of global climate change, a fact that is almost universally agreed upon by the world’s scientists by now. Refuge managers have to be prepared to update their expectations for various populations sizes as the climate changes. This is not a static world, it is illogical to acts as if it is.

9. Biodiversity is incredibly important to maintain the health of the global ecosystems as well as the local ecosystems. It has been understood for half a century or more that removing the predators leads to a decrease in the health of prey populations. Thus any further destruction of the Mountain Lion population could well have a detrimental impact on the Bighorn Sheep and Mule Deer populations. There is no definitive data to support the theory that Mountain Lions are newcomers to the Kofa NWR.

10. A Wildlife Refuge should have the wildlife as the primary concern. Considering that there was no decrease in hunting permits sold to hunters, let alone an elimination of hunting permits, during the panic over the sheep herd decrease, it highlights the fact that the decisions to kill the two mountain lions were absolutely unethical. Correspondence that is now part of the public records clearly shows that the hunting groups demanded the death of the mountain lions in return for their prior financial support, stating:

“Mr. Hovatter, Why haven’t you returned my email? Is this true this lion has made TWO kills now. On bighorn sheep! I need the dates and locations of these kills. Acording (sic) to the usf&w paper we supported ($138080) two strikes in 6 months and the lion goes to the bid (sic) kofa in the sky. When is his date he does have a collar!! Read the following after my info. I do out source for info.”

Jim Broschart ADBSS Treasurer

I’ll repeat – this email was obtained as part of the public records search, and clearly shows the lack of ethics in the decisions to kill the mountain lions.

11. There are some artificial water sources that have been added to the Kofa NWR to sustain potentially higher than normal populations of the Bighorn Sheep. An additional water source was added more recently (illegally, as it was done in secrecy, without an environmental assessment and public comment), which potentially had a detrimental impact to any young lambs or gravid ewes in the area. Furthermore, and this is just one reason an environmental assessment absolutely should have been done, increasing the water holes is likely to have a corresponding increase on mountain lion predation ranges.

In conclusion, I recommend a policy to be enacted of no hunting of mountain lions on Kofa NWR by agencies or hunters. The agency biologists should be conducting non-lethal observational research to learn more about the Kofa populations so that in the future any decisions made are informed by accurate science, rather than the biases of local hunting groups. Mountain Lion experts should be consulted to fill in the gaps of knowledge of the agency biologists.

I thought I’d post my letter, sent last night, in case it would help anyone else in their letter writing.

Comments can be sent to:

SnailMail: U.S. Fish and Wildlife Service, 356 W. 1st St., Yuma, AZ 85364

Comment deadline is Monday, June 23, 2008.


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