Off Target 11: Time running out for lions, bears and your comments


In mid-December, the USDA-APHIS-Wildlife Services (WS) released its pre-decisional Draft Environmental Assessment for its predator damage management in Colorado. The draft is now in its 45-day public comment period, which ends on Jan. 24. After that, WS will issue either a Finding of No Significant Impact and move to finalize the assessment, or a Finding of Significance, which would require the agency to complete a full and much more detailed Environmental Impact Statement by Aug. 1, 2018.

If you have followed BW’s 10-part “Off target” series, you’ll recall that WS was contracted to do predator damage management as part of the Colorado Department of Parks and Wildlfe’s (CPW) $4.6 million Piceance Basin and Upper Arkansas River Predator Control Plans.

WS agreed to prepare a new Environmental Assessment after being sued by the Center for Biological Diversity (CBD) and WildEarth Guardians (WEG). The suit largely came about because of WS’s role in CPW’s predator control plans.

These plans, experts argue, are based on the scientifically questionable premise that mule deer populations in Colorado aren’t growing rapidly enough because of predation from mountain lions and black bears. Thus, CPW has proposed killing the predators as a path to increasing deer populations with WS in charge of the killing.

In their lawsuit, the environmental groups allege the best available science reveals loss of habitat is the driving cause of mule deer population decline in Colorado, and the best available science reveals predator control is not effective at increasing deer populations in Colorado.

CBD and WEG point to massive impacts from oil and gas extraction and associated infrastructure in the Piceance Basin as the actual cause of the mule deer’s struggle.

“We believe the original EA had a number of serious errors and we will be reviewing the new draft EA closely to see if those errors have been resolved,” says Andrea Santarsiere, senior attorney for CBD.

In the Draft EA, WS has withdrawn neither their participation in CPW’s predator control plans nor their assistance with CPW’s efforts to protect mule deer from mountain lions or black bears by killing those animals.

CPW has agreed to pay WS $50,000 per year for three years to kill mountain lions and black bears in the Piceance Basin with traps, hounds, snares and, eventually, a lethal shot from a firearm. The killing will occur during the months of May and June.

For unknown reasons, CPW is withholding results from this year’s tax-payer funded predator killings, having refused numerous requests by BW made under the Colorado Open Records Act (CORA).

The Draft EA states WS’s mountain lion killing may have a moderate impact on lion populations, but this conclusion appears to be largely a guess. Neither WS nor CPW have site-specific population numbers on which to base such a conclusion.

The Draft EA also states the agency killed an average of 72 black bears per year from 2012-2016, adding it anticipates an increase in this number, up to 200 per year due to a bear population that is supposedly increasing. At least part of the reason for this assumption that the bear population is on the rise has been attributed to the increasing number of human-bear conflicts.

However, CPW’s own research project near Durango that was led by Heather Johnson found that bear-human conflicts cannot be taken as proof of a growing bear population. As previously reported in “Part 5” of this series, Johnson’s six-year study found that rising temperatures around dens and urban development in black bear habitat shorten hibernation, which creates more conflicts with people. And if increased suburban expansion leads to decreased bear populations and more human-bear conflicts, as Johnson found, then CPW’s policy of determining bear hunting quotas based on these conflicts may be actually causing bear populations to decline exponentially.

Johnson’s work appears to directly contradict WS’s assertions in its new Draft EA.

And just last week — early January — bears were sighted in the southwestern Colorado towns of Durango and Telluride, which is cause for concern according to Johnson’s study. CPW says bears usually leave hibernation in mid-March, and this year’s unnatural early awakening — in the context of an extremely warm and dry winter influenced by climate change — is likely a portent of things to come. Will human-bear conflicts stemming from this dangerous change in climate be used as an excuse for even more increased predator killing? If the Draft EA is to be believed, then the answer is likely yes.

Again, despite a lack of actual numbers on which to base its analysis, WS concludes that impacts to bear populations overall from its controlled killing, “will be negligible.”

Like Johnson’s research, the environmental groups challenging the predator plans in court believe that killing the animals at this time of increasing temperatures and drought, which are likely attributable to climate change, could spell disaster for Colorado’s mountain lion and black bear populations.

“We believe that the matters analyzed herein may have significant environmental impacts,” Santarsiere says, “especially on wildlife and public lands, and therefore we believe an Environmental Impact Statement is necessary. If Wildlife Services does not complete an Environmental Impact Statement, we are likely to end up in court again.”

Meanwhile in the Piceance Basin, Rio Blanco County Commissioners have been meeting with energy officials and investors from Japan while coordinating further delegations with Department of Interior Deputy Secretary and former Brownstein Hyatt Farber Schreck energy lobbyist David Bernhardt and other Southeast Asian countries, including China. It’s likely these meetings are an effort to establish relationships and markets for the estimated 66 trillion cubic feet of natural gas underlying the Piceance Basin.

According to the research, more natural gas exports mean more climate change, more drilling on Colorado’s public lands and more habitat loss for mule deer.

It’s unclear what WS and CPW will kill next in its efforts to offset the oil and gas industry’s impact on deer populations. But if history is an indicator, it won’t be oil and gas leases on our public lands.

To leave a comment on the Draft Assessment, you have until Jan. 24. Visit:


  1. A setting up stilted studies to support three killing of our wildlife so the greed and self interest of certain interests is a very destructive and outrageous way to go. The impact of these careless actions will definately felt even if not immediately and then may be too late to reverse. You should learn from previous mistakes.


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