February 9, 2023

Dear Bureau of Land Management Representatives…..

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Dear BLM Reprentatives:

Since the BLM has elected to extend the comment period regarding the Idaho Predator Derby the request of an Oregon Congressman, please let me provide what I suggest is some rational comment in the face of substantial emotional comment you have received in opposition to the Derby. Since wolves cross state lines, I will refrain accusing the Oregon Congressman from “poaching,” even though he stands in opposition to almost all positions on everything taken by the Idaho congressional delegation. Likewise, I would not portend to deny the expression of opposition to the Predator Derby, much of which has a quality of quasi-religious species preference for wolves expressed by wolf advocates.

I do suggest, however, that a more rational comparison of the Predator Derby might be made to fishing derbies, where families gather to have fun and teach the young to fish (see attached). The Forest Service apparently took that view in ruling that no permit was needed for the Predator Derby (see attached). The species preferences for wolves exhibited by some people who live elsewhere should not be given any more weight than a preference, let us say, for the “iconic” rainbow trout. The Idaho Predator Derby is presented as a family event for people whose culture it is to engage in hunting in a place where these people practice this culture live (see attached).

The BLM’s economic analysis found that while the town of Salmon and surrounding areas might receive a $94,000 boost, the state as a whole could miss out on anywhere from $23,800 to $2,380,000 depending on how many people decide to not visit the state due to opposition propaganda. Clearly, it is difficult to quantify exactly how much the state will lose in economic activity. Past experience has shown, however, that the tourist industry has not been particularly affected by activist propaganda. I would suggest that the economic analysis might be more accurate if it took into consideration the positive affect that the predator hunting derby might have on the greater hunting community. Available Idaho Fish and Game statistics show the substantial reduction of non-resident hunting licenses and the related substantial drop in income that the State of Idaho Fish and Game Department has suffered since the introduction of wolves and the consequential devastation of the elk herds in certain of Idaho’s 28 elk hunting zones. The predator hunting derby in conjunction with Idaho’s efforts to control wolves would most certainly serve as a relevant inducement to that specific community of non-resident hunters to return to Idaho. I suggest that it is more likely that the predator Derby will have a positive economic impact overall, primarily because of its effective emphasis on control of predators through hunting and the message it sends to greater hunting community.

The Opposition claims that the Environmental Assessment failed to adequately address an alternative SRP request for a wildlife viewing contest submitted by Western Watersheds Project and Center for Biological Diversity which, if the permit is issued, would take place instead of the derby or at the same time. By all rational analysis, this is a political effort to deny the people of Salmon and the hunters of Idaho their planned hunting derby – an event located in their own community. The nature of this effort by the opposition can be better understood by simply referring to the websites of these organizations to clearly see such effort for what it really is: A money raising campaign based on crass exploitation of anthropomorphic sympathies engendered by such propaganda. It has the quality of the bucket being passed at a revival meeting.

The Derby sponsors have attempted to comply with every procedural step, including early filing to avoid delaying tactics of the opposition. Accordingly, it is respectfully suggested that the BLM grant the application for a permit, if the decision is made that a permit is needed.

Best Regards,

John L. Runft
Runft & Steele Law Offices, PLLC
1020 W. Main St., Suite 400
Boise, Idaho 83702