Help Stop a Killing Contest on National Forest Lands!
- by: Defenders of Wildlife
- recipient: U.S. Secretary of Agriculture, Tom Vilsack
Despite the Bureau of Land Management (BLM) rightly withdrawing its permission for a "hunters' rights" organization to hold a commercial predator killing contest on 3 million acres of public lands, the sponsors of the derby are still determined to move forward - so they're planning to hold it on national forest and private lands.
We need to make it clear once and for all that the federal government should not be in the business of approving 19th century predator killing tactics.
The U.S. Forest Service needs to do its job and ensure that national forest lands are protected for the enjoyment of all Americans. BLM stepped up for predator conservation, and now it's time for the Forest Service to step up as well.
Please take immediate action and tell Secretary Vilsack to close our national forests to Idaho's appalling wolf and predator killfest!
We need to make it clear once and for all that the federal government should not be in the business of approving 19th century predator killing tactics.
The U.S. Forest Service needs to do its job and ensure that national forest lands are protected for the enjoyment of all Americans. BLM stepped up for predator conservation, and now it's time for the Forest Service to step up as well.
Please take immediate action and tell Secretary Vilsack to close our national forests to Idaho's appalling wolf and predator killfest!
Dear Secretary Vilsack,
I write to request that the Forest Service notify the sponsors of the proposed predator derby that they are not authorized to utilize the Salmon-Challis National Forest (SCNF) for their predator derby. According to the sponsors, up to 500 participants would compete on private, state, and national forest lands to kill the most wolves, coyotes, and other wildlife in a competition for cash prizes.
Earlier this year, the sponsors submitted applications to both the SCNF and to the Idaho Falls District of the Bureau of Land Management (BLM) seeking authorization to hold the derby on public lands. After public comment periods which generated nearly 100,000 comments opposing the derby, BLM initially approved the derby but rescinded its approval shortly thereafter.
In contrast, the Forest Service has not yet required a permit, held public comment, or evaluated the impacts in response to the sponsors' request for a Special Use Permit. Rather, the Forest Service notified the sponsors by letter dated August 19th, 2014 that no permit was needed to hold the derby on the SCNF lands.
The Forest Service's August 19th determination was wrong. Forest Service regulations provide that all uses of national forest lands are "special uses" and must be authorized by the Forest Service through issuance of a Special Use Permit. 36 C.F.R. 251.50(a). Use and occupancy of national forest lands without a Special Use Permit is prohibited. 36 C.F.R. 261.10(k). Certain activities are exempt from the Special Use Permit requirement, including noncommercial recreational activities, such as hiking, fishing, and hunting. 36 C.F.R. 251.50(c). But hunting and other recreational activities do require a Special Use Permit if the activity is a commercial event or a noncommercial group use, and the Forest Service has consistently treated events like the proposed derby as either a "commercial event" or as a "noncommercial group use" requiring a Special Use Permit.
Even if the derby is not commercial, a Special Use Permit is still required as it is a "group use" event, defined as "any activity conducted on National Forest System lands that involves a group of 75 or more people, either as participants or spectators." 36C.F.R. 251.51. The sponsors seek to have up to 500 participants plus an unknown number of spectators use the SCNF to competitively hunt in the derby. This far surpasses the 75-person threshold for a group use.
By failing to require a Special Use Permit, the Forest Service has avoided its duty to evaluate important criteria for protecting our public lands. As already mentioned, BLM held two public comment periods during its permitting process which generated nearly 100,000 total public comments, nearly every one of which expressed opposition to the derby.
In light of the above, the Forest Service should reverse its position and deny the use of national forest service lands for this commercial predator derby.
Therefore, I request that you immediately direct the Forest Service to promptly inform the sponsors that derby participants are not authorized to utilize national forest lands for its event and that the sponsor not offer competitive credit for wildlife taken on these lands until the Forest Service properly reevaluates the sponsors' proposal.
[Your comments will go here]
Sincerely,
[Your name here]
Sign PetitionSign PetitionI write to request that the Forest Service notify the sponsors of the proposed predator derby that they are not authorized to utilize the Salmon-Challis National Forest (SCNF) for their predator derby. According to the sponsors, up to 500 participants would compete on private, state, and national forest lands to kill the most wolves, coyotes, and other wildlife in a competition for cash prizes.
Earlier this year, the sponsors submitted applications to both the SCNF and to the Idaho Falls District of the Bureau of Land Management (BLM) seeking authorization to hold the derby on public lands. After public comment periods which generated nearly 100,000 comments opposing the derby, BLM initially approved the derby but rescinded its approval shortly thereafter.
In contrast, the Forest Service has not yet required a permit, held public comment, or evaluated the impacts in response to the sponsors' request for a Special Use Permit. Rather, the Forest Service notified the sponsors by letter dated August 19th, 2014 that no permit was needed to hold the derby on the SCNF lands.
The Forest Service's August 19th determination was wrong. Forest Service regulations provide that all uses of national forest lands are "special uses" and must be authorized by the Forest Service through issuance of a Special Use Permit. 36 C.F.R. 251.50(a). Use and occupancy of national forest lands without a Special Use Permit is prohibited. 36 C.F.R. 261.10(k). Certain activities are exempt from the Special Use Permit requirement, including noncommercial recreational activities, such as hiking, fishing, and hunting. 36 C.F.R. 251.50(c). But hunting and other recreational activities do require a Special Use Permit if the activity is a commercial event or a noncommercial group use, and the Forest Service has consistently treated events like the proposed derby as either a "commercial event" or as a "noncommercial group use" requiring a Special Use Permit.
Even if the derby is not commercial, a Special Use Permit is still required as it is a "group use" event, defined as "any activity conducted on National Forest System lands that involves a group of 75 or more people, either as participants or spectators." 36C.F.R. 251.51. The sponsors seek to have up to 500 participants plus an unknown number of spectators use the SCNF to competitively hunt in the derby. This far surpasses the 75-person threshold for a group use.
By failing to require a Special Use Permit, the Forest Service has avoided its duty to evaluate important criteria for protecting our public lands. As already mentioned, BLM held two public comment periods during its permitting process which generated nearly 100,000 total public comments, nearly every one of which expressed opposition to the derby.
In light of the above, the Forest Service should reverse its position and deny the use of national forest service lands for this commercial predator derby.
Therefore, I request that you immediately direct the Forest Service to promptly inform the sponsors that derby participants are not authorized to utilize national forest lands for its event and that the sponsor not offer competitive credit for wildlife taken on these lands until the Forest Service properly reevaluates the sponsors' proposal.
[Your comments will go here]
Sincerely,
[Your name here]
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