Invisible Voices

a voice for the voiceless

Kofa Lions: Draft Environmental Assessment comment period through 10/2/09

Two and a half years ago, I wrote a post about the Kofa National Wildlife Refuge Mountain Lions. I’ve been writing about them periodically ever since. They’re under attack, and there are precious few people speaking up for them.

Ron Kearns is one of those people. I count on him to keep me updated, to help me understand what is going on behind the scenes at Kofa, and what the next steps in this long process are. He left a comment on an earlier Kofa Lion post today, and it really needs to be it’s own post. So, here’s what Ron has to say:

Please consider commenting on the Draft Environmental Assessment for Limiting Mountain Lion Predation on Desert Bighorn Sheep on the Kofa National Wildlife Refuge.

The Draft EA (DEA) is open until Oct 2, 2009, or 1-month, 8 days from today. The following discussion explains my support for the ‘No Action Alternative A’ as the best option—to date—that allows mountain lions to exist on Kofa NWR.

Once the FWS receives public comments, agency reviewers are supposed to consider all comments fully and modify the 3 Alternatives—or perhaps consider other new Alternatives—to reflect substantive recommendations by the public. However, the FWS replied to a PEER request inquiring about the public’s opportunities to further comment on the changes to the Alternatives recommended by the public. Southwest Arizona NWR Complex Manager Ellis stated that no more open, public comment periods would be available for the next step of the process, the Final EA (FEA) and a most often associated document, the Finding of No Significant Impact (FONSI). Therefore, whatsoever consideration the FWS might give to modifying the Alternatives—based on the public’s DEA comments—the government’s decision is final with a signed FONSI. The only recourse for the public that I know of at this point is to appeal to the District Court affirming that the FONSI did not sufficiently address the full range of reasonable Alternatives submitted by the public and therefore did not comply fully with NEPA requirements.

On other outcome could be a determination by the agency that the public DEA comments exposed enough concerns that an Environmental Impact Statement (EIS) is required. If that occurred, the Public Scoping and Public Comment period would begin anew. See a NEPA Decision Making flowchart here:

There are 3 Alternatives available in the DEA. I suggest that you strongly consider the No Action Alternative A as the best option to save the greatest number of mountain lions for the longest possible time. There may be modifications of Alternative A that you might suggest that could further enhance the longevity of research data from GPS-collared Kofa mountain lions before they are killed once they leave the refugium of Kofa NWR.

Unfortunately—and by USFWS/AGFD design—all 3 Alternatives in the DEA allow for the killing of Kofa lions, just at different rates and at different geographic locations. Therefore, if the USFWS is not going to allow Kofa lions that are captured and GPS-collared for research on Kofa to live and roam freely throughout the refuge and environs—and without a successful lawsuit to counter this killing—then the No Action Alternative A will at least not permit the State AGFD or anyone else to enter upon Federal refuge lands to kill lions that have preyed upon 2 or more bighorn sheep in 6 months. The ‘offending lions’ would have to leave the protection of the Federal refuge onto the public lands of BLM or other jurisdictions. That situation exists today in the area known as the Kofa Mountains Complex, which includes Kofa NWR and adjacent areas, and would continue to exist under the No Action Alternative A, as it is currently written before the review of DEA public comments.

The current GPS-collared tom lion—KM04—is scheduled to be shot by Arizona Game and Fish Department staff once he leaves the boundary of Kofa NWR. Lion KM04, similar to the previous 2 collared Kofa lions that were killed, will be easily tracked down to a general area by satellite GPS location data. Then the final pinpoint location for the kill is achieved through the collar’s accessory VHF transmitter beacon sending location signals that are picked up by a handheld VHF frequency antenna by the shooters on the ground. Sometimes there is the additional assistance of a VHF antenna affixed to an aircraft that provides the ground crew with updated locations of the lion.

Thank you,
Ron Kearns
Retired Kofa NWR Wildlife Biologist, USFWS
Former Federal Collateral Duty Refuge Law Enforcement Officer, USFWS

The press release and additional information regarding the Draft Environmental Assessment can be found on the Kofa National Wildlife Refuge site.

If this is the first Kofa Lion post of mine you’re reading, you might find it helpful to read some of the other posts I’ve written. The most relevant to the Draft EA is “Kofa lions granted reprieve“.

I add my encouragement to Ron’s: please consider writing. This is not an issue that gets attention from the organizations in this movement. We are it. Whatever incredibly small number of us write letters have an enormous impact, because unlike when you get alerts from the movement groups, there is no one else writing the letter if you don’t. This matters. Our actions count. Please write.

5 responses to “Kofa Lions: Draft Environmental Assessment comment period through 10/2/09

  1. Ron Kearns August 25, 2009 at 11:09 pm

    Deb et al.

    I wanted to include a copy of Alternative A so that people could get a quick glimpse of its contents. Most people who frequent Invisible Voices know their decision immediately regarding the killing of sentient beings, including wildlife. Therefore, since the FWS disingenuously jumped from a Lion Management Plan during the EA Public Scoping comment period to a definitive and lethally entitled… *Limiting* Mountain Lion Predation on Bighorn plan in the DEA, I ask your support for Alternative A as the best available ‘option’ to save lions for the longest period until they venture outside the Kofa boundary. The FWS ignored the Scoping comments from people who wanted no killing whatsoever of Kofa mountain lions and did not include those in a more accurate No Action Alternative, as they should have done. The very title of the current Plan effectively limits and restricts our comments to how many and where lions are killed. However, that should not prevent people from still commenting in the DEA to save lions from any death by humans within the boundary of Kofa NWR. Simply stipulate—in your own words—that if the Service refuses to consider public comment- based Alternatives that prevent all GPS-collaring that could lead to lion killings, that you—without much choice except through possible litigation—support Alternative A: No Action Alternative.

    Furthermore, if you are pressed for time in this hectic life and know that you want to allow for as many mountain lions as possible roaming free and wild on Kofa National *Wildlife Refuge*, e-mail your brief comment simply stating that you support the No Action Alternative A.

    E-mail comments to

    From the DEA page 13


    3.1 Alternative A: No Action Alternative – Continue Current Management Efforts

    Under the No Action Alternative, the Refuge would continue to be managed as it has been in the
    past. This is considered the environmental baseline, or status quo. Since bighorn sheep
    management and mountain lion predation management outside the Refuge have been conducted
    in Arizona for decades, the environmental baseline can be considered as including the effects of
    the current ongoing programs. The wildlife population baselines are those that are in place under
    the current condition of the human environment which means they incorporate and reflect the
    populations as they have been and are being affected by humans.

    The Service currently has no Refuge-wide plan to guide the management of mountain lions.
    Current management efforts, described in USDI 1997 focus on the maintenance of critical
    wildlife water sources for bighorn sheep, and, in annual coordination with the AGFD, monitor
    desert bighorn sheep and mule deer numbers, set the number of hunt permits, and consider desert
    bighorn sheep transplants to augment populations elsewhere in the region. Research on wildlife
    and wildlife water sources would continue. Collection of mountain lion scat for composition
    analysis and the collaring of mountain lions and desert bighorn sheep would continue. The study
    of desert bighorn sheep health and causes of mortality on the Refuge would continue.

    The Service would not take action to prevent mountain lion predation on desert bighorn sheep
    within the Refuge boundaries under this alternative.

    End Quote}


  2. Deb August 28, 2009 at 6:36 pm

    Thanks for including this, Ron.

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