American Sheep Industry Photo

Call to Action--Protect Predator Management Tools

December 28, 2007

Dec. 28, 2007 -- The Environmental Protection Agency (EPA) received a petition from animal rights groups requesting the agency to cancel all uses of M-44 sodium cyanide capsules and Compound 1080 claiming that these substances cannot perform their intended functions without causing unreasonable adverse effect on the environment and posing an imminent hazard. The EPA is requesting comments from interested parties in response to this request.

The American Sheep Industry Association (ASI) and the state sheep associations are working diligently to assure that the EPA is provided accurate information as it relates to M-44 and Compound 1080 and are asking farmers and ranchers to let your voice be heard by submitting your own comments.

"We expect hundreds of comments from the predator advocates requesting EPA to cancel these predator control tools, so it is very important that we also have hundreds of sheep producer comments in opposition of this request," commented Peter Orwick, ASI executive director. "ASI provided an informational mailing this week to sheep producers nationwide requesting comment on this critical issue."

Compound 1080 is a substance used in livestock protection collars and sodium cyanide is used in a capsulated form in M-44 ejectors. The M-44 is second only to aerial hunting in controlling coyotes for predator management in the United States. As coyotes are, by far, the number one predator, loss of a tool such as the M-44 would have a negative impact. Both substances are effective and efficient predator control tools used by Wildlife Services to protect not only livestock but also threatened and endangered species from predation by fox, coyotes and feral dogs. They are environmentally sound, registered by the EPA and used only by trained and certified applicators.

Comments, both mailed and submitted electronically, must be received on or before Jan. 15, 2008, to be considered. Access to the Federal Register can be obtained at http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-22369.htm.

To submit your comments via mail, the following address should be used: Office of Pesticide Programs (OPP); Regulatory Public Docket (7502P); Environmental Protection Agency; 1200 Pennsylvania Ave., NW; Washington, D.C. 20460-0001. Also include this additional information in a subject line to assure proper handling: Comments to Docket ID number EPA-HQ-OPP-2007-0944; Petition Requesting EPA to Issue a Notice of Intent to Cancel the Registrations Of M-44 Sodium Cyanide Capsules and Sodium Fluoroacetate; Federal Register Volume 72, Number E7-22369, pages 64623-64624.

Electronic comments can be submitted by going to http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&d=EPA-HQ-OPP-2007-0944-0010. Click on the orange symbol next to "Add Comments" and type in your comments. You will be asked to identify your comments by docket identification number EPA-HQ-OPP-2007-0944.

Please mention your opposition to the petition requesting the EPA to cancel the registration of sodium cyanide capsules for M-44s and sodium flouroacetate for livestock protection collars.

In your comments, it will be helpful to let the EPA know that you are a sheep producer and to mention if predator control is a regular part of your sheep operation. Describe both the lethal control and the nonlethal control methods you utilize to manage losses to predators. Finally, include your answer to the following question: Will the elimination of more predator management tools increase the death loss of sheep to predators on your operation?

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