July 22, 2018

For Maine: Consideration of More Restrictive Trapping Regs, Could Become Costly to Canada Lynx

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Below, please find a copy of the letter I have sent to the U.S. Fish and Wildlife Service for comments being received concerning the State of Maine application for an Incidental Take Permit for trapping and the Canada lynx.

January 13, 2012

U.S. Fish and Wildlife Service
Maine Field Office
17 Godfrey Drive, Suite 2
Orono, Maine 04473

To Whom it May Concern:

The Endangered Species Act, from the time of its inception being signed into law by President Nixon in 1973, is intended to prevent the needless extermination of species and to implement plans to protect and recover any species that is determined to be “endangered” or “threatened” according to certain criteria contained within the Act.

Maine is attempting to recover a species of Canada lynx and are presently involved in obtaining an Incidental Take Permit (ITP) for its trapping industry that is workable and in the best interest of the lynx recovery as well as doing what is in the best interest of maintaining a healthy ecosystem for the people of Maine.

As part of the application process for ITP, the U.S. Fish and Wildlife Service (USFWS), is seeking harsher restrictions for trapping regulations, including equipment modifications and limitations. According to the application and the Environmental Assessment, the USFWS is seeking input on the following items that they believe to be required for lynx protection and recovery:

Require lynx-exclusion devices for all killer-type traps at land sets, including elevated sets on poles and trees, in WMDs 1-11, 14, 18 and 19.
Require that all trappers phase in foothold traps meeting BMP standards for fox, coyote and bobcat over the next 5 years and rescind existing jaw-spread restrictions once BMP trap requirements are fully implemented.
Eliminate the use of drags and require short chains, swivels or in-line springs for foothold traps at land sets in WMDs 1-11, 14, 18 and 19.
Limit the use of killer-type traps at land sets, including elevated sets, to size #120 (5-inch) and smaller in WMDs 1-11, 14, 18 and 19.
Require 24-hour check of all killer-type traps at land sets, including elevated sets, in WMDs 1-11, 14, 18 and 19.
Require pan-tension devices on all foothold traps at land sets in WMDs 1-11, 14, 18 and 19.
Limit the use of foothold traps at land sets in WMDs 1-11, 14, 18 and 19 to the months of October and November only.
Prohibit trapping with land sets (including elevated sets) in WMDs 1-11, 14, 18 and 19.
Require periodic re-training of all trappers on how to avoid incidental lynx captures.

Maine is presently under a court-ordered Consent Decree (Animal Protection Institute v. Roland D. Martin – Civil Action No.: 06-cv-00128-JAW, Document 134) This Consent Decree, as ordered by the Court is to remain in effect until the State of Maine obtains an ITP from the U.S. Government. This Consent Decree was filed on October 4, 2007. Since that time, it is my understanding through unnecessarily difficult information to obtain, that only two Canada lynx have been “incidentally” taken, resulting in death to the species. It is also my understanding that both of these events were deemed accomplished through illegal acts and no death of lynx have occurred as the result of all legal regulations agreed to in the Consent Decree. It is for this explanation that it must be questioned as to the reasoning of further restrictions on trapping in and/or outside of critical lynx habitat areas.

Please consider also the following information:

The U.S. Fish and Wildlife Service, has published on their own website, a study entitled, “Habitat Fragmentation and Interspecific Competition: Implications for Lynx Conservation”. That specific publication lists several species that are competitors in both habitat and prey for the lynx. It also clearly defines the coyote as the leading competitor of the lynx.

On page 91 of referenced document, you’ll find the following information:

“The coyote, because of its wide habitat niche, heavy predation on snowshoe hares (O’Donoghue et al. 1998), high reproductive rate (Quinn and Parker 1987), great behavioral plasticity (Murray and Boutin 1991), and high tolerance of humans (Litvaitis 1992), must be considered a potentially formidable competitor with mesocarnivores, including the lynx. Indeed, coyotes are suspected in various declines of mesocarnivores, as evidenced by documented cases of coyotes competing with or preying on sensitive and endangered species (reviewed by Litvaitis 1992 and Goodrich and Buskirk 1995).”

According to Maine’s Game Plan for Deer, coyotes present a problem in 1.) being a part of the reasons for a depleted whitetail deer herd, and 2.) a continued and growing presence prohibits efforts in recovering that species of deer.

The concern then becomes whether further restrictions on trapping, which will result in limiting a trappers ability to remove coyotes from not only deer habitat but the very habitat that the Canada lynx relies on for sustainability, while speaking little of growth.

I have been unable to find any studies that can tell us to what point do we strive to save lynx from trapping activities, that the end result is the death of more lynx via competition than is attempting to be saved? It is my concern that the USFWS consider this concept before implementing further restrictions on trapping.

If the Maine Department of Inland Fisheries and Wildlife is so restricted through unnecessary trapping laws, resulting in the further loss of whitetail deer, the state does, through the Endangered Species Act (10j), retain the right to apply for a permit to kill coyotes to save deer. This could become costly and complicated for both the state of Maine and the U.S. Government, when perhaps more careful consideration of the rules governing the ITP could ward off such actions.

Because nature does not “balance” itself in any idealistic fashion, man works hard at managing our fields and forests for health. At would run contrary to the Endangered Species Act and its intended goals, in consideration of protecting one species, it cannot come at the loss of another.

If the intended goal is to continue to rebuild the Canada lynx in Maine, consideration of all aspects is in the obvious best interest of not only the lynx but all species and the people of Maine.

It is my wish that the USFWS will thoughtfully consider that further actions to restrict trapping, could create a larger negative feedback in your efforts to recover the lynx by allowing for the increased growth of a direct competitor.

Thank you for your consideration.

Respectfully,

Thomas K. Remington
Largo, Florida/Bethel, Maine

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