Officer Wayne,

I would like to report the following alleged wildlife violations in your region.

1. 31 counts of sterilization of coyotes without a permit.
This activity apparently involves USFWS biologists and the veterinary clinics that performed the sterilizations.

Evidence:

From USFWS January – March 2013 Quarterly Report –

http://www.fws.gov/redwolf/Images/20130416_RedWolf_QtrReport_FY13-02.pdf

“Thirty-one coyotes were captured and released during the quarter, 29 of which were first-time captures. All captured coyotes were sterilized before being radio-collared and released, and consisted of eight males and 23 females.”

USFWS had no sterilization permit during this time period.

It is my strong belief that this activity was repeated again from January through May of 2014. The USFWS reports for this period have not been published. USFWS keeps a “canid book” which will have the information you need.

There was no sterilization permit in place for this period either.

In addition, I believe USFWS has been sterilizing coyotes in our State for almost 15 years. Please cross-reference the trapping and sterilization documentation in their quarterly reports with the issuance of the required permits during this time period. There are likely hundreds of violations.

2. Trapping out of season without a permit.

Evidence:

See the above referenced evidence.

Additionally, this USFWS presentation documents their trapping schedule is daily September through April.

https://docs.google.com/file/d/0B4hb-L8j0UYebzNkdFFPakRWSXM/edit

“•? Trapping (Sept-April) •? Daily”

3. Trapping on the land of another without written permission.

Evidence:

I have requested information regarding this activity from USFWS and have not yet received it. Since 90% of the red wolf packs and the vast majority of coyotes occur on private land, I suspect this activity to be rampant. Again, the USFWS “canid book” information and lack of written permission from landowners should suffice as evidence. I have additional first hand information if you need it.

4. Releasing coyotes on the land of another without permission.

Evidence:
“FWS biologists have also tried bringing in sterilized coyotes to the area. The idea is those sterile animals will keep other coyotes out of the wolf territory and lower the risk of hybridization.”

http://www.timberwolfinformation.org/nc-north-carolina-red-wolf-also-subject-of-conservation-controversy/

I suspect coyotes were trapped, sterilized and released on my farm in Tyrrell Co. in the Spring and Summer of 2013 by USFWS biologists. I never granted permission for anyone to release coyotes on my property. USFWS while at the office of the NCWRC Director was specifically directed by me to euthanize any trapped coyotes on my property. The USFWS should have this data. Again, the “canid book” should have this data.

It is well documented that USFWS regularly purchases coyotes from trappers. I can only assume these purchased coyotes are later released and likely released on private property without permission.

5. Purchase of live coyotes, entrapment, misrepresentation.

In the State of NC, it is illegal for wildlife to be bought and sold. One exception is that a coyote or fox may be sold only to a fox pen. Now, if special conditions that I am unaware of allow USFWS to purchase wildlife, will you confirm that these conditions were fully met at all times. It will be a real shame if local trappers (selling live coyotes to non fox pen buyer) and veterinarians (sterilization of wildlife) have jeopardized their livelihoods because they were led to believe that they were participating in a legal activity as it was represented to them by the USFWS. I will also copy Roy Cooper, as if my suspicions are correct, he will need to get involved in this matter.

Evidence:

“This year, we had 8 trappers participate and we paid out $5,200 for 32 coyotes and 10 red wolves.” 4/4/13 letter USFWS to RWC
I can provide this letter when necessary.

Officer Wayne, I take these alleged violations seriously and request to be updated regularly on their status.

Also, are you comfortable that the deer used to feed the wolves in the acclimation pens and also the deer that are laced with medications and wormers for the “wild” wolves are taken legally (all required permits and landowner permissions)? Thank you for your help.

Sincerely,

Jett Ferebee

http://www.nchuntandfish.com/forums/showthread.php?103801-USFWS-Red-Wolf-Recovery-Team-Reported-for-Alleged-Wildlife-Violations-by-Jett-Ferebee

http://www.nchuntandfish.com/forums/showthread.php?95624-quot-Red-Wolf-quot-restoration-scandal

Mr. Ferebee,
Thank you for your referral. The Service takes all allegations of misconduct very seriously. On March 26, 2015, this office initiated an investigation into allegations made by another concerned party into the Red Wolf Program. The case number for this matter is FWS-2015-24. I would ask your patience as we look into this sizable program. If you have any questions, feel free to contact me at the below numbers. -Keith
—
_________________________
K. A. Toomey, #640
Special Agent in Charge
Professional Responsibility Unit
US Fish & Wildlife Service

ESA Section 7 Violations by USFWS – Red Wolf Program

Date: Tue, Mar 31, 2015 2:18 pm
Attachment
Secretary Jewell, Director Ashe, and Ms. Harvey,

The Endangered Species Act of 1973 requires US Fish and Wildlife Service to conduct intra-agency consultation for its own actions that may impact listed, proposed, and candidate species and designated and proposed critical habitat. In 1986, USFWS filed the attached ESA Intra-agency Section 7 Consultation regarding the red wolf introduction into North Carolina. Please note 3 of the 4 evaluators stated the intended action “may affect” the red wolf population.

The attached Section 7 Consultation document explicitly states that USFWS will remove 10 (but up to 12 animals) from the captive red wolf population for release onto the Alligator River National Wildlife Refuge with an estimated incidental take of only 2 animals.

USFWS, over the next five years removed 43 (not 10 or even 12) animals from the captive population. 14 of these 43 wolves were released onto private land outside of the Alligator River National Wildlife Refuge without legal authorization or the protections offered by the refuge system.

22 of the 43 animals (not 2), removed from the captive population died within 5 years of their release. (See the 1992 ARNWR report: http://www.fws.gov/uploadedFiles/anr-ar-pi-1992.pdf and the attached FOIA wolf release document)

To date USFWS has now removed 132 wolves out of the captive population of which 64 were illegally released onto private land. 60 out of 64 (93.75%) of all suspected illegal takes have occurred on private land. Internal USFWS policy is to discourage removal of wolves from private land.

The 1986 Section 7 Consultation document states:

“If during the course of the action the amount of extent of incidental taking previously specified is exceeded, the refuge manager and the field supervisor must reinitiate consultation immediately.”

Ms. Sharneka,

Please provide the required Section 7 Consultation for the removal of an additional 120 “red wolves” (132 – 12 approved) from the captive breeding population.

Please provide the required Section 7 Consultation to sustain an incidental take beyond the 2 estimated animals as required in the 1986 Section 7 Consultation.

Please provide the Section 7 Consultation to release wolves on private land and to not remove wolves from private land where the wolves are less protected.

Please provide the Section 7 Consultation providing for the released of red wolves outside of their historic range. (see attached USFWS Red Wolf Historic Range map)

Secretary Jewell and Director Ashe,

It is important to note that the Red Wolf Recovery plan sets the needed captive population at 330 animals. After more than 30 years, this captive population only has 197 very closely related individuals. The entire red wolf population is highly susceptible to inbreeding as it was started with only 14 so called “red wolves”. Now, only six of these founder wolves are represented in the wild.

Has the unauthorized “take” of 120 red wolves from the captive breeding population by USFWS personnel now jeopardized the existence of the red wolf species, if indeed it is a species?

Has the unauthorized “take” of 120 red wolves by USFWS irreparably harmed the red wolf “species” by further causing an inbred population both in the wild and in captivity?

Has the unauthorized release of red wolves onto private land and the failure to remove wolves from private land by USFWS resulted in “USFWS self inflicted” losses that now jeopardize and adversely impact the existence of the red wolf species, if indeed it is a species?

Has the unwillingness for USFWS personnel to abide by hardly any of the Endangered Species Act rules governing the red wolf introduction in eastern NC, now so eroded private landowner support that a successful reintroduction of the red wolf can never be achieved anywhere?

Has the release of red wolves outside of their historic range by USFWS personnel adversely impacted or jeopardized the existence of the “red wolf species”? (see attached USFWS Red Wolf Historic Range map)

I thank you for your time.

Sincerely,

Jett Ferebee

Special Agent in Charge Keith Toomey,

Thank you so much for creating a case file and investigating the alleged NC Wildlife law violations by USFWS Red Wolf personnel.

Probably more concerning and serious is the alleged illegal “take” of 120 red wolves by USFWS Red Wolf personnel. Additionally, USFWS red wolf personnel have released a nonessential experimental population of wolves outside of it’s historical range, which is a violation of the ESA 10(j) rules.

“The PRU conducts both criminal and administrative investigations for the Service of other non-law enforcement Service employees when asked based on the seriousness of the alleged offense.”

Will the USFWS Professional Responsibility Unit please investigate the ESA Section 7 and the ESA 10(j) rules violations by the USFWS – Red Wolf Program personnel as outlined in the below email?

Copy of FOIA Letter re: Section 7 Consultation requirement