USDA Wildlife Services responds directly to BAX co-director over petition
An Animal Rights Article from


Robert Merrick, Bird Ally X
June 2014

[Ed. Note: Also read How Many Wolves Died for Your Hamburger?]

Last week, I initiated a petition on, as an individual, to the three people responsible for the Department of Agriculture’s ‘wildlife damage control’ program, known as Wildlife Services. Secretary of Agriculture, Tom Vilsack; USDA-APHIS, administrator Kevin Shea; and APHIS Wildlife Services deputy administrator, William (Bill) H. Clay. (Read more about Wildlife Services.)

Within a day, the petition had gathered 500 signatures. At about the time that it passed that number, 500, I received an email from Bill Clay, deputy administrator for USDA-APHIS Wildlife Services. While it’s odd that he has replied directly to me, rather than to, which also didn’t share my email address, I am glad that USDA staff are aware that public light is being cast on Wildlife Services.

In any case, Bill Clay wrote to me, and I wrote him back. Here’s what we had to say to each other...

On 20 Jun 2014, , at 12:39, Clay, Bill H – APHIS wrote

Mr. Merrick,

In regards to your Change.Org petition expressing concerns over our program, let me address some of your concerns by clarifying the misinformation that you have heard or read about the Wildlife Services (WS). First, WS works closely with State and Federal wildlife agencies which regulate resident and migratory birds and threatened and endangered species and which set management goals for various wildlife populations. The professional wildlife agencies strongly support our program and recognize the need to manage wildlife damage as part of responsible wildlife management and the North America model of wildlife management. Lethal take is an important component of wildlife management.

While the concern expressed regarding the lethal removal of over 4 million animals during an entire year over the entire United States is noble, it indicates a lack of understanding of overall wildlife populations, mortality, recruitment and population dynamics. Quoting raw numbers, taken out of context, without indicating the overall wildlife population or other sources of species mortality is irresponsible. Although it generates an emotional response it does not indicate the overall impact to wildlife populations. For example, cats kill from 1.3 to 4.0 billion birds each year in the United States. Hunters harvest over 50 million mourning dove each year out of a population estimated to be well over 300 million birds. More than one million deer-vehicles collisions occur annually, often deadly to deer, which have a population of over 30 million deer. Disease, predation, age, and many factors all contribute to wildlife mortality.

Our lethal take last year involved the removal of approximately 3.5 million birds, nearly 80% of which were invasive species. A Presidential Executive Order 13112 on Invasive Species (Section 2) clearly directs Federal agencies to control invasive species and prevent their spread. I understand that many people object to the use of lethal control; however, regulated hunting and trapping is an important tool to manage overabundant wildlife populations and is supported by professional wildlife biologists and wildlife agencies that are mandated to manage them.

In responsible [sic] to the allegations of being a secretive and unaccountable program, anyone who has ever reviewed our website knows that Wildlife Services annually provides the Program Data Reports and other information, including budget information, (which your petition requests) and has provided this information for over 20 years. Through the website we seek to inform the public of actions as a responsible and accountable federal program. The recent Washington Post article criticizes our program because of the numbers of animals killed each year. It’s ironic that we make this information available each year regarding how many animals are killed, species, methods used, nontarget take, etc., and then are criticized for not being accountable to the public.

During the past 5 years, WS has invested more than $50 million to identify and develop new nonlethal methods of control. Most of the effective nonlethal methods currently used by farmers, ranchers, and the public has either been developed or tested by our program.

The implication that WS is mainly funded by Federal dollars is also incorrect. Over $100 million non-Federal dollars is provided to WS each year from the people that request our services. In fact, WS is one of the very few Federal agencies where the recipients of our services pay at least half, and in some cases 100 percent, of the cost of the project.

Articles about WS often fail to indicate that over 80 percent, or 18 million animals, are moved or dispersed each year by WS using nonlethal methods, or that we work at most airports across the country to protect airplanes and people; that we protect over 150 threatened and endangered species for other wildlife threats; or that we conduct one of the largest programs in the world to stop the spread of the Mid-Atlantic strain of rabies commonly carried by raccoons in the Eastern United States. The article also failed to document that the WS program is managed by professional wildlife biologists. To obtain accurate information on the WS program, please visit our website.

William H. Clay
Wildlife Services

Here is my reply

Mr. Clay,

Thank you for taking the time to respond directly to me in regard to the petition I initiated on

As you know, the 50,000 people who have signed this petition so far are not the only critics of the opacity of USDA-APHIS Wildlife Services.

In December 2013 Wildlife Services was petitioned by Center for Biological Diversity, Project Coyote, Animal Welfare Institute, and Animal Legal Defense Fund to begin the rule-making process for the same reasons I started the petition; that is, to bring transparency and accountability to WS, to ensure humane treatment of animals, and to protect public safety and interests. (read legal petition)

I am sure that you are aware of the highly regarded series published in the Sacramento Bee in 2012 that sheds light on a governmental branch that operates outside of the values of most Americans. Covering up unintentional kills, shooting animals from helicopters, irresponsible use of poisons, suffocating and burning young mammals in their dens – these are revolting, unnecessary and cowardly acts. Citizens have a right to know how their contribution through taxes (whether federal, state, county or municipal) are spent, and a right to object to these repugnant practices. Suggesting that such well-documented and long criticized practices are either necessary or insignificant is a failure to address our petition. We are petitioning for information regarding these kills, not excuses or rationalizations.

Transparency and accountability demand more than the assertion that critics are misinformed. As a wildlife professional, I am well aware of the numbers of birds, mammals, reptiles and amphibians that are killed or injured by various anthropogenic causes, such as feral and free-roaming domestic cats, vehicle traffic, windows, wind farms, toxic pollution and so on.

You reference the large number of birds killed by cats and imply that such a high mortality somehow absolves WS of wrongdoing for the lesser number of animals reported to be killed WS agents. These are unrelated issues. Mass fatalites are not judged against each other but against what is right. Besides this point, in regard to the numbers of animals reported to be killed by WS agents, the figures provided by your agency are not trustworthy, especially in light of former agents who have consistently described the culture of “shoot, shovel, and shut up” that permeates WS.

And none of these issues that plague WS are new. Multiple reviews and reports, from as early as Olaus Murie’s 1931 internal report, through the Cain Report from early 1972 (formally titled Predator Control 1971: Report to the President’s Council on Environmental Quality by the Advisory Committee on Predator Control, S.A. Cain, et al) have clearly indicated that Wildlife Services practices are out of step with science, decency and democratic values. While critics have consistently identified these key areas for reform, this agency, under various names, has consistently failed to enact these reforms in a meaningful fashion.

The history of Wildlife Services is not a noble one, nor has it met its purported mission. Even the federally mandated task of invasive species control that you reference (which is the reason for the existence of Wildlife Services, from its inception as the Division of Economic Ornithology in 1885) has been a failure. As an example, House Sparrows, which your agency’s first administrator sought to “attack and destroy,”* launching Wildlife Services’ official methodology, have been neither eradicated nor controlled.

Frankly, your response to this petition appears to be further stonewalling. It is easy to understand why Congress member Pete DeFazio has referred to WS as the “one of the most opaque and obstinate” agencies he’s encountered. Moreover, for the administrator of the WS program, with its history of wolf eradication, well-documented cruelty, and broadcast use of highly toxic poisons across our natural heritage, among other reprehensible actions both large and small, to accuse one who questions these practices of being “irresponsible” neither addresses the concerns nor is befitting your role as a public servant.

Monte Merrick

(*) C. Hart Merriam, MD was the first director of the Division of Economic Ornithology, established inside the Department of Agriculture July 1, 1885. After a year, the division was expanded to include Mammology and soon after that the word Economic was dropped. In his first annual report Merriam discussed areas for USDA work, for legislative action, and for general recommendations. While regarded by his own Department as an impediment to its mission to eradicate avian and mammal economic threats to agriculture, here’s what Merriam had to say about House Sparrows: “The English Sparrow is a curse of such virulence that it ought to be systematically attacked and destroyed before it becomes necessary to deplete the public treasury for the purpose, as has been done in other countries.” PDF here.

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