Wildlife Services Contract Renewed

Posted on July 29, 2014 by Monte Merrick

Wild places and wild things constitute a treasure to be cherished and protected for all time. The pleasure and refreshment which they give man confirm their value to society. More importantly perhaps, the wonder, beauty, and elemental force in which the least of them share suggest a higher right to exist–not granted them by man and not his to take away. – Richard M. Nixon, 1972

67 Coyotes, 9 Mountain Lions, 38 Black Bears, 235 Striped Skunks, 218 Raccoons, 57 Opossums, 17 Gray Fox – animals reported killed by Wildlife Services in Humboldt County between 2010 and 2013.

We are deeply disappointed with the Humboldt County Board of Supervisor’s decision to renew our County’s contract with one of the US Government’s least accountable agencies, Wildlife Services, whose illegal activities, cover-ups, opacity, and lack of regulatory framework have been as well-documented as possible given that very opacity. Still, we are glad for the opportunity to have much needed discussion regarding this agency’s activities in our own backyard. Past contract renewals have slipped by without notice. With an approach to human/wildlife conflicts as outdated and entrenched as Humboldt County’s it certainly must be true that it will take more than a couple of hours of 3-5 minute public comments to undo decades of poor practices.

Humboldt Wildlife Care Center operates in every district of Humboldt County as well as Northern Mendocino, Del Norte, Trinity, parts of Siskiyou and even Curry County in Oregon across the state line. We respond to calls regarding injured, orphaned, and so-called nuisance wildlife every day of the year. We run on the proverbial shoestring budget, utilizing volunteer labor and relying on the generosity of our community. We assist with any problem, and when something is beyond our local capacity, we have resources around the State and the Nation on which we can rely.

The decision to renew the contract is disappointing, not only because it legitimizes past unnecessary wildlife kills, and not only because of the future unnecessary wildlife kills it will allow, but also because it undermines the public education and outreach work on which HWCC/BAX spends a significant amount of resources.

Incredibly, it was even suggested by the Supervisors that HWCC/BAX could collaborate with Wildlife Services. With our commitment to co-existence, to the intrinsic value of wild animals, to non-lethal measures, transparency, and accountability to our community, obviously we find little in common with the branch the Sacramento Bee calls the “Killing Agency.” Our work in this county, to promote co-existence between people and our wild neighbors, to educate on the laws regarding how wild animals may be treated, competes with the County’s diametrically opposed message.

Trapping wildlife does not solve human/wildlife conflicts. Trapping doesn’t address or control rabies. The circumstances that bring a wild animal into conflict with people are most often, if not always, sources for food, water or shelter that are provided, intentionally or not, by people – often by the same people experiencing the problem. Removing these provisions usually results in the wild animal moving on – trapping and killing the animal changes nothing, leaves the attractant in place for other animals, risks orphaning any young of the trapped animal, and needlessly applies a capital penalty on the wild animal for a human transgression. In short, trapping is lazy, cruel and ineffective. Humane solutions are not only ethically superior, humane solutions last.

The Board’s statement, that there is no problem that needs to be addressed, displays a callous disregard for the lives of countless wild animals who have been killed without cause, their disrupted families, and also the values and concerns of a majority of people everywhere. According to Humboldt County Agricultural Commissioner Jeff Dolf, since 1921, Humboldt County has contracted with Wildlife Services. The number of animals senselessly killed over the last 9 decades would be astonishing if it were calculable.

The Board of Supervisors has neither the the knowledge or experience to make decisions on these matters. Presented with legitimate concerns regarding a controversial program, it is our view that the Supervisors did not perform due diligence in seeking alternative perspectives from knowledgeable sources. Rather than research the issue, members of the Board stood by childhood playmates, gross misapprehensions of disease vectors and a poor understanding of the successes of more advanced programs in other counties. The decision to continue contracting with Wildlife Services does a disservice to the County, to the citizens of this County who deserve better leadership, and to the wild animals who have as much right to their existence as we have to ours.

We of course will carry forward with our mission. We will continue to provide quality care for injured and orphaned wildlife, to partner with trustee agencies to provide non-lethal solutions for human/wildlife conflicts and embrace and support the progress our culture has shown in our ability and willingness to share in the bounty of Mother Nature.

While we wish to find a way forward toward a more humane future for Humboldt County and California, it would be negligent of us, as citizens of this county and as one of the many voices for this county’s wild residents, if we did not express our sorrow and disappointment with the Board’s decision and the deeply flawed reasoning that produced it.

Meanwhile, please take a look at this online petition to bring transparency and accountability to Wildlife Services. If you’ve already signed it, please share it with your circle of friends and colleagues. https://www.change.org/petitions/wildlife-services-stop-slaughtering-millions-of-wild-animals

P.S. This kind of advocacy work may not cost us much in food, medicine or other resources, but it does take time. Please contribute what you can. Help us supply the ounce of prevention… Thank you for your support and for your love of wildlife

Wild Babies Need Your Love!

Posted on July 24, 2014 by Monte Merrick

Check out our new eNews, just sent out today!

Wild Babies Need Your Love! (it’s true, they do!)

Like the eNews? sign up by following the link to the right————->

Fire Wildlife Services! Local Organizations’ Letter to Humboldt County

Posted on July 19, 2014 by Monte Merrick

Bird Ally X; Environmental Protection Information Center
North Group, Redwood Chapter, Sierra Club;
Klamath Forest Alliance; Friends of the Eel River
________________________________________________________________________________________________________
July 18, 2014
Humboldt County Supervisors
825 5th St., Room 111
Eureka, CA 95501

Re: Support for Terminating Humboldt County’s Contract with APHIS-Wildlife Services
Dear Supervisors Bohn, Fennel, Bass, Lovelace, and Sundberg,

The undersigned organizations write to express our support for the June 30, 2014 request from the Animal Legal Defense Fund (ALDF), the Center for Biological Diversity, and other groups to terminate Humboldt County’s contract with the U.S. Department of Agriculture’s APHIS- Wildlife Services (Wildlife Services) and bring the county’s wildlife control activities into compliance with the California Environmental Quality Act (CEQA).

The Wildlife Services program relies on antiquated and cruel methods to kill wildlife, and it operates under a heavy veil of secrecy despite being funded by taxpayer dollars. Non-lethal alternatives are time-tested and prove to cost less while being more effective in protecting livestock, and we urge Humboldt County Supervisors to join Marin County, Sonoma County, and the City of Davis in moving toward an alternate approach.

According to the Washington Post, Wildlife Services killed more than 4 million animals last year alone, including 75,326 coyotes, 866 bobcats, 528 river otters, 3,700 foxes, 973 red-tailed hawks, and 419 black bears.1

The agency uses snares, traps, poisons, and aerial gunning to kill wild animals, often killing pets and other non-target animals by mistake. An investigative series by the Sacramento Bee found that between 2000 and 2012, Wildlife Services “accidentally” killed more than 50,000 non-problem animals, more than 1,100 dogs, and several imperiled species – including bald and golden eagles.2

In addition to endangering outdoor recreationists and their pets, these practices disrupt the natural balance of wildlife populations, degrade habitat, and increase disease, causing the “loss of many ecosystem services that benefit human society directly and indirectly.”3

In spite of these impacts, Wildlife Services operates with a complete lack of transparency or oversight of its actions, and has steadfastly refused requests from the public, lawmakers, and others to disclose details on the lethal methods it employs, the poisons it uses, and how its money is spent.

Bipartisan members of Congress, including Elton Gallegly, R-Calif., and Jackie Speier, D-Calif. are calling for national reforms and requested a congressional investigation of the program. And due to related questions and controversies, the Office of Inspector General is now conducting an audit of Wildlife Services.

Marin County ended its contract with Wildlife Services in 2000, choosing instead to develop and implement its Livestock and Wildlife Protection Program, which assists ranchers with livestock protection in a nonlethal manner. The Marin County Agricultural Commissioner calls it a “good move” that substantially reduced livestock losses to predators, saying it cost more to operate in the beginning than today, but it now operates at about half the cost as it did under the Wildlife Services contract.4

The City of Davis voted unanimously to end its contract with Wildlife Services in January 2013 after the agency killed five coyotes, including four pups, without consulting City staff, which “did not concur that these animals exhibited behavior that warranted removal.”5

The City of Davis now implements a Coyote Management and Coexistence Plan at an estimated cost of $8,000 a year. Sonoma County also recently elected to forego its contract with Wildlife Services and is now exploring a program similar to the one used in Marin County.

We encourage you to take this opportunity to take the lead of other local governments and help establish a regional model the rest of the nation can emulate. Humboldt County citizens are known for their environmental ethics and forward-thinking ideas. The time has come to end the outdated practices employed by Wildlife Services here, and to come together as a community to realize a better solution that protects our public trust resources and values.

Sincerely,

Monte Merrick
Bird Ally X
PO Box 1020 Arcata, CA 95518
mm@birdallyx.net

Natalynne DeLapp
Environmental Protection Information Center
145 G Street, Suite A Arcata, CA 95521
natalynne@wildcalifornia.org

Diane Fairchild Beck, Conservation Chair
North Group, Redwood Chapter, Sierra Club
PO Box 238 Arcata, CA 95518
dfbeck@northcoast.com

Kimberly Baker
Klamath Forest Alliance
PO Box 21 Orleans, CA 95556
kimberly@wildcalifornia.org

Scott Greacen
Friends of the Eel River
PO Box 4945 Arcata, CA 95518-4945
scott@eelriver.org

1) Fears, D., USDA’s Wildlife Services killed 4 million animals in 2013; seen as an overstep by some, Washington Post (June 7, 2014)

2) Knudson, T., The killing agency: Wildlife Services’ brutal methods leave a trail of animal death, Sacramento Bee (Apr. 28, 2012)

3) Bergstrom, J.B., Arias, L.C., Davidson, A.D., Ferguson, A.W., Randa, L.A. & Sheffield, S.R., 2013, License to kill: reforming federal wildlife control to restore biodiversity and ecosystem function, Conservation Letters, v. 6, p. 1-12

4) Scully, S., Sonoma County’s contract for wild animal control under fire, Press Democrat (June 1, 2013)

5) Staff Report from Robert A. Clark, Interim Public Works Director, City of Davis to Davis City Council (Jan. 15, 2013)

Alert! Humboldt County Board of Supervisors to Consider Wildlife Services contract July 22

Posted on July 17, 2014 by Monte Merrick

Your voice is needed!

Humboldt County’s Board of Supervisors, after postponing discussion of the county’s contract with USDA Wildlife Services, also known as “the Killing Agency,” at their July 1 meeting, will re-open the discussion this Tuesday, July 22. (For more information, look here and here)

As regular readers of Bird Ally X know, USDA Wildlife Services has a long and ignoble history, dating back to the late days of the 19th century and westward expansion. From extermination of Gray Wolves to the senseless killing of baby Raccoons, no matter where we look, Wildlife Services is bad news for wild animals.

If you live in Humboldt County, please telephone your District Supervisor and ask that she or he votes to sever the contract with Wildlife Services.

Rex Bohn, District 1 Supervisor and Board Chairperson , 707-476-2391
Estelle Fennel, District 2 Supervisor and Vice Chairperson, 707-476-2392
Mark Lovelace, District 3 Supervisor, 707-476-2393
Virginia Bass, District 4 Supervisor, 707-476-2394
Ryan Sundberg, District 5 Supervisor, 707-476-2395

You can also send an email: (find your Supervisor’s email address here.)

Here is a sample letter that you can use, or write your own:

Subject line: Sever the Contract with Wildlife Services
Sample letter: I write to ask you to sever the Humboldt County contract with Wildlife Services.

I oppose USDA Wildlife Services’ involvement in lethal wildlife management for several reasons. The agency lacks a regulatory framework, and behaves like a rogue agency that is totally out of control and accountable to no one. Members of Congress are demanding accountability from Wildlife Services, which is now being investigated by the USDA Inspector General for mismanagement and is under increasing public scrutiny for killing over two million native animals and pets last year alone, including thousands of coyotes, black bears, foxes, mountain lions, and other animals in California. Wildlife Services cannot be trusted to carry out any lethal wildlife control, period.

Under the county contract, Wildlife Services would also kill raccoons and skunks that den beneath people’s homes. But as a recent incident in Humboldt County revealed, when a federal trapper trapped and killed a mother raccoon and left her babies to starve and die beneath a Humboldt County home, the program conducts these activities in a cruel and inhumane way.

Traps and snares for coyotes and other species jeopardize other wildlife in California including endangered Gray wolves as they return to their native range in northern California – an unacceptable risk that Wildlife Services would simply sweep under the rug.

There are much better ways for Humboldt’s citizens to co-exist with wildlife, without the killing and cruelty. I don’t want Wildlife Services targeting Humboldt County’s wildlife.

The main thing is to let your Supervisor know that it’s unacceptable to use our tax dollars for cruelty and ignorance. We’ve had enough shadowy, unaccountable wildlife killing! Urge your supervisor to seize the moment. Let Humboldt County be among those who leads the way to non-lethal humane resolution for human/wildlife conflicts.

Our wild neighbors on the North Coast deserve much better than USDA Wildlife Services. Thank you for your love of wildlife and thank you for taking action!

Your support makes our work caring for injured and orphaned wildlife, and advocating to prevent needless injury to wildlife possible. Please donate what you can. Thank YOU!

A young crow returns

Posted on July 9, 2014 by Monte Merrick

As if they were all on the same schedule, about 3 weeks ago young crows all over Humboldt County were making their first leaps toward independence by jumping out of their nests. As we remind everyone, this is wild baby season. All over the county, and everywhere, young animals are learning the ways of the world. For songbirds like crows, this means weak and a little clumsy flight long after they leave the nest. They are vulnerable to all sorts of dangers, and in our modern world many of these dangers are man-made – cars, windows, cats, and more. And some times they are at risk of false imprisonment.

When the Eureka Animal Control Officer Rob Patton pulled up in our driveway 2 weeks ago, we greeted him at the door.

“Got you a young crow,” he announced. We’ve worked with Eureka PD Animal Control for a long time. While many people might mistakenly nab a poorly flying young bird, thinking help is needed, Officer Patton knows whether a wild animal needs help or not.

Turns out the young crow landed in the equipment yard at the Police Station. They watched him for a week before deciding that no parents were nearby. So they booked him. Another lost fledgling – a definite youth at risk.

The crow was very underweight and quite excited to meet his food dish. Crows, like people, are omnivores – eggs, fruit, fish, mice, seeds, insects made up his diet. Gradually we moved him to larger housing where his flight improved.

Yesterday, we took him back to his old neighborhood. Not far from the police station, at the Eureka waterfront, is a common foraging place for crows and other birds. BAX/HWCC intern, Cheryl Henke and BAX co-director and photographer Laura Corsiglia scouted for crows.

Satisfied that this would be a good place for the young crow, they let him out of the carrier.

Almost immediately an adult crow came to him. The young crow gaped (opening his mouth wide to ask for food).

“I was astonished,” exclaimed Cheryl, “It was beyond belief. It was like they already knew each other!”

The adult quickly coaxed the bird from the ground to a nearby treetop. After some brief conversation, the two birds flew off together.

Your support allows us to sometimes pull off rescues as profoundly beautiful as this. Please donate what you can. Help keep wild families together, or perhaps, build new ones!

(all photos Laura Corsiglia/BAX)

Humboldt County Board of Supervisors Puts Contract Renewal With Wildlife Services on Hold

Posted on July 3, 2014 by Monte Merrick

EUREKA, Calif.— One day after a broad coalition of national animal and conservation groups urged the Humboldt County Board of Supervisors to terminate its contract with the U.S. Department of Agriculture’s Wildlife Services, the board assented to a citizen request to delay consideration of contract renewal for at least a month in order to reevaluate the issues.

At its meeting on Tuesday, the board had scheduled a vote on the county’s annual renewal of its contract with Wildlife Services, a federal program that kills tens of thousands of native wild animals in California every year. But on a citizens’ request submitted by local wildlife rehabilitator Monte Merrick, the board decided to remove the renewal item from its consent calendar, delaying it at least another month as the county considers the issues raised by Merrick and the coalition.

“I am elated that the board has agreed to consider whether to renew its contract with Wildlife Services,” said Merrick. “Wildlife Services is increasingly controversial and there are better options to address wildlife conflicts.”

The coalition groups sent a formal letter asking the county to undertake an environmental review and ensure proper protections — as required under California state law — prior to hiring Wildlife Services to kill any additional wildlife. Last year, in response to a similar letter from the Animal Legal Defense Fund, Sonoma County’s Board of Supervisors opted not to renew the county’s contract with Wildlife Services and is now conducting a review of its wildlife policies. Marin County cancelled its contract with Wildlife Services 14 years ago and implemented a nonlethal predator-control program. As a result the county has seen a 62 percent decrease in livestock predation at one-third of the former cost.

Since 2000 Wildlife Services has spent a billion taxpayer dollars to kill a million coyotes and other predators across the nation. The excessive killing continues unchecked despite extensive peer-reviewed science showing that reckless destruction of native predators leads to broad ecological devastation. The indiscriminate methods used by Wildlife Services have killed more than 50,000 “nontarget” animals in the past decade, including endangered condors and bald eagles. The program recently released data showing that it killed over 4 million animals during fiscal year 2013 using a variety of methods, including steel-jaw leghold and body-crushing traps and wire snares. These devices maim and trap animals, who then may take several days to die. In 1998 California voters banned several of these methods, including leghold traps.

“Humboldt County has a chance to be a leader in California wildlife management by eliminating their contract with Wildlife Services,” said Stephen Wells, executive director of the Animal Legal Defense Fund. “Nonlethal predator control has proven to be more humane, more cost-efficient, and more effective — it’s simply the right thing to do for the county.”

“We are glad to see that Humboldt County is pushing the ‘pause’ button on its relationship with Wildlife Services,” said Tim Ream of the Center for Biological Diversity. “We hope that the county will do the wise thing and terminate its relationship with Wildlife Services altogether.”

“Humboldt County has an opportunity to do what’s right here by reviewing their contract with Wildlife Services and shifting towards a nonlethal program that is ecologically, economically and ethically justifiable,” said Camilla Fox, Project Coyote founder and executive director, who helped develop Marin’s nonlethal program. “We pledge our assistance to the county toward this end and urge the Board of Supervisors to emulate the successful Marin County Livestock and Wildlife Protection Program that provides non-lethal assistance to ranchers.”

“The last thing the county that is home to such special places as the Lost Coast and Redwood National Park should be doing is allowing Wildlife Services to trap and kill its native wildlife,” said Elly Pepper, an NRDC wildlife advocate. “Using nonlethal methods to balance its incomparable natural beauty with its critters is a much better use of county residents’ money.”

“It is time to put aside the unchecked assumption that wildlife conflicts can only be solved via Wildlife Services’ draconian, outdated killing methods,” said Tara Zuardo, wildlife attorney at the Animal Welfare Institute. “We salute Humboldt County for stepping back to reevaluate its options — a move that will hopefully lead to more humane, less costly and more effective methods of wildlife management.”

Contact:

Megan Backus, Animal Legal Defense Fund, (707) 795-2533 x 1010 (office); (707) 479-7872 (mobile); mbackus@aldf.org
Tim Ream, Center for Biological Diversity, (415) 632-5315; tream@biologicaldiversity.org
Camilla Fox, Project Coyote, (415) 690-0338 (mobile), cfox@projectcoyote.org
Josh Mogerman, Natural Resources Defense Council, (312) 651-7909; jmogerman@nrdc.org
Tara Zuardo, Animal Welfare Institute, (202) 446-2148; carson@awionline.org
Tim Dunbar, Mountain Lion Foundation, (916) 442-2666 x 105; tdunbar@mountainlion.org
Monte Merrick, BAX/Humbodlt Wildlife Care Center, (707) 832-8385; mm@birdallyx.net

A letter to the Humboldt County Board of Supervisors #WildlifeServices

Posted on July 1, 2014 by Monte Merrick

27 June 2014

Humboldt County Board of Supervisors
Rex Bohn, Chairperson

re: cancel contract with USDA-APHIS Wildlife Services

Dear Supervisor Bohn, et al

I am writing to you regarding the County’s contract with USDA-APHIS Wildlife Services.

I am sure that each of you is aware of the controversial nature of this branch of the Department of Agriculture. The controversy stems, not simply from the use of lethal measures to address human/wildlife conflicts, but from the secretive nature of the program, from the documented cruelty practiced by some of its agents, from the documented instances of endangered species, threatened species and family pets that have been killed unintentionally, from the cases of illegal activity committed by Wildlife Services (WS) agents that have been exposed without repercussion, from the systemic lack of accountability of the program at all levels.

These problems are well known. They have also been documented over the course of many decades, beginning with the early 1930s (Olaus Murie’s internal report, 1931) through the Sacramento Bee’s 2012 series, The Killing Agency.

These practices, which are wholly unbefitting a government agency, are also in direct opposition to moral values, scientific knowledge, principles of adaptive management, and the desires of the American people.

My own experiences with Wildlife Services have forced me to conclude that the agency’s culture is prone toward rogue violence.

While responding to the worst petroleum pipeline spill in the United States – the Kalamazoo Spill in Michigan in 2010 – I worked in the field with WS. US Fish and Wildlife personnel eventually forced WS agents to partner with wildlife caregivers due to their consistently inhumane methods of capturing oiled wildlife. At one point the entire response was jeopardized by WS agents insistence that oiled Canada geese be shot rather than rescued. Fortunately, more intelligent and compassionate arguments prevailed. If they hadn’t this would have been the first time in US history that victims of an oil spill had been killed rather than rehabilitated – a violation of federal laws (e.g., Migratory Bird Treaty Act, Oil Pollution Act of 1990).

Sadly, we don’t need to leave Humboldt County to find examples of WS’s shadowy cruelty. In May, Humboldt Wildlife Care Center(HWCC) received a call from a member of the public who was angry and distressed about baby raccoons who had been left to die under her mother’s house.

Her mother had called Animal Control of the Humboldt County Sheriff’s Office to seek assistance with an animal under her home. She was given the number of the county trapper. Identifying himself as Wildlife Services, he told the homeowner that the animal was a male raccoon with no babies. Now, this alone is highly suspicious. Why else would a raccoon be using a crawlspace in Spring?

After he had trapped and killed the raccoon, who of course was a female, and after the babies died and began to rot and smell, the homeowner tried to reach him, but to no avail. Then they called us. We went under the house, removed the dead babies, who were exactly where we would have looked if they had called us first – in the void between the built-in tub and the wall.

I have tried to reach the “county trapper” but he has not returned my calls. I have also asked the county for any reports that APHIS-WS submits regarding their contractual activity in Humboldt County. I have received no response.

HWCC, every day of the year, counsels members of the public who have wildlife conflicts. These problems are easy to resolve without resorting to lethal measures. We do this without charge! Our phone number is widely available. Our information is made public on the internet, through print journalism, through radio public service announcements and through word of mouth. This is our area of expertise – an expertise earned the old-fashioned way: on the front lines.

We maintain a Humane Solutions team that is available for everything from consultation to doing the physical work of humanely convincing a wild animal to leave an area and then making the necessary adjustments to ensure the problem is solved.

Of course it is true that most human wildlife conflicts are caused by poor human practices. Given this, resorting to lethal means, except in the cases of immediate threats to public safety (e.g, confrontations with Bears and Mountain Lions) is unjustifiably immoral.

On June 19, I started a petition on Change.org to the administrators of the Department of Agriculture responsible for APHIS-WS. The petition demands standards of transparency and accountability be applied to APHIS such as every other government agency is legally required to meet. After 11 days the petition has received over 70,000 signatures. It is safe to say that citizens of every stripe do not want wildlife assassins working without accountability, out of public view, free to use whatever lethal means they wish, and with no repercussions. I can certainly say that I don’t.

I encourage this Board, and its individual members, to dig deeper into what this agency does, what it reports, what it covers up. The agency’s culture of “shoot, shovel and shut up” is well documented if not well known. This is not an issue of right versus left or conservative versus liberal. The actions of WS, when they become known, are horrible to hunter and vegan alike. The repugnant actions of Wildlife Services do not fill a void, they create one. They create a void where our values would be.

Thank you for considering eliminating the $67,000 portion of our county’s budget that is set aside for cruelty and ignorance. I hope unreservedly that the amount spent in 2013-14 is the last time that Humboldt County spends taxpayer money on something so reprehensible. Humboldt Wildlife Care Center/Bird Ally X are available to help build a more humane future for human/willdife co-existence.

Sincerely,
Monte Merrick

For more information and for a list of some sources to look further please visit the Bird Ally X site and look at this post. http://birdallyx.wordpress.com/2014/06/17/opaque-and-obstinate/

To view the Change.org petition: https://www.change.org/petitions/wildlife-services-stop-slaughtering-millions-of-wild-animals

To view the petition to initiate rule-making that was brought by Center for Biological Diversity, Project Coyote, and others: http://www.biologicaldiversity.org/programs/biodiversity/pdfs/Wildlife_Services_Rulemaking_Petition_Dec_2_2013.pdf