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National Wildlife Refuge System; Biological Integrity, Diversity, and Environmental Health

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Animal Welfare Institute filings
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Animal Welfare Institute filed 1 comment on this docket between Feb 29, 2024 and Feb 29, 2024. 60 other organizations filed here. The comment window closed 813d ago.

What Animal Welfare Institute filed (1)

Feb 29, 2024· Comment from Animal Welfare Institute· FWS-HQ-NWRS-2022-0106-18370

February 28, 2024 Via Federal eRulemaking Portal Public Comments Processing Attn: FWS-HQ-NWRS-2022-0106 United States Fish and Wildlife Service 5275 Leesburg Pike, MS: PRB (JAO/3W) Falls Church, VA 22041-3803 RE:National Wildlife Refuge System: Biological Integrity, Diversity, and Environmental Health (Docket No. FWS-HQ-NWRS-2022-0106) Dear Director Williams: The Animal Welfare Institute ("AWI") submits the attached comments in response to the proposed regulations submitted by the U.S. Fish and Wildlife Service ("USFWS") regarding the biological integrity, diversity, and environmental health of the National Wildlife Refuge System ("NWRS"), 89 Fed. Reg. 7,345 (Feb. 2, 2024). AWI is dedicated to alleviating animal suffering caused by people. We seek to improve the welfare of animals everywhere: in agriculture, in commerce, in our homes and communities, in research, and in the wild. Since 1951, AWI has advanced its mission through strategically crafted policy and legal advocacy, educational programs, research and analysis, litigation, and engagement with policymakers, scientists, industry, educators, other NGOs, the media, and the public. We seek scientifically-grounded protections for animals in all settings, and robust enforcement of those protections. This comment is limited to the aspect of the proposed regulations that would prohibit predator control on NWRS lands. Id. at 7,352 (Section 29.3(d)(1)). AWI strongly supports this aspect of the proposed regulations due to the essential role that predators play within healthy ecosystems. The proposed regulations, however, identify five management activities that USFWS does not consider to be predator control activities within the meaning of proposed Section 29.3(d)(1). Id. These activities constitute significant exceptions to the prohibition on predator control. To the extent that these five identified management activities will involve the use of lethal methods to manage predators, AWI respectfully requests that USFWS incorporate into the final regulations a prohibition on the use of body-gripping traps, as defined below in Section II, when engaging in these five management activities due to the inhumaneness and indiscriminateness of these devices. If, despite the compelling evidence provided in this comment, USFWS does not include a ban on the use of body-gripping traps in this context, AWI encourages USFWS to set a mandatory trap check time of no more than 24 hours and also require the use of trap monitors for certain types of traps when the devices are used to carry out the five management activities listed in the proposed regulations. For a full discussion of these issues, please see the attached documents. Sincerely, Johanna Hamburger Director and Senior Attorney Terrestrial Wildlife Program Animal Welfare Institute

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Abstract

Please see the supporting and related materials in this docket for a document that summarizes the proposed rule.

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Co-filers (60)

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National Wildlife Refuge System; Biological Integrity, Diversity, and Environmental Health (FWS) — Animal Welfare Institute | OpenPolis