Predator control guised as rabies protection: EPA rejects Texas bid to bring back Compound 1080

From ANIMAL PEOPLE, Jan/Feb 1995:

AUSTIN––The Texas Department of Agriculture thought
it might sneak reauthorized Compound 1080 predator poisoning past
the Environmental Protection Agency and an unaware public in the
guise of rabies control. It nearly succeeded.
One of the deadliest chemicals ever deployed against
wildlife, with no known antidote, 1080 is actually a trade name for
sodium fluoroacetate, developed by the Nazis as a nerve gas during
World War II. It came to the attention of the U.S Animal Damage
Control program in 1946, after the now defunct American Journal of
Public Health published the results of LD50 testing done on human
prisoners. Impressed with the lethality and ease of use of 1080, the
ADC quickly adapted it for use against coyotes, killing
millions––along with greater millions of nontarget species, accord-
ing to ADC records, and an average of about one human being per
year. High-profile cases of misuse brought the deaths of three small
children and a firefighter, in separate incidents. Finally, in February
1972, then-U.S. president Richard Nixon banned 1080 by executive
order from both federal use and any application on federal land.

Later in 1972, the newly formed EPA yanked the registra-
tion for 1080 to keep it out of private use––a precaution that kept it
officially off the market, except in the form of poison-laden collars
for sheep and goats, until under pressure from ranchers, another for-
(continued on page 12)
mer president, Ronald Reagan, lifted the ban on January 28, 1982.
The proposed Texas poisoning was to target gray foxes,
identified as the main rabies carrier in the 43 counties to have been
involved, which had 39 confirmed rabies cases among them
between June 30 and September 30, 1994. Red foxes, coyotes,
bobcats, raccoons, striped skunks, and ringtails might also have
been poisoned, the TDA acknowledged, but named them too as
potential rabies carriers. Coincidentally, red foxes, bobcats, and
especially coyotes are the species most vocally hated by the
livestock industry.
Quietly filed on August 4, the TDA application to
seed the landscape with 1080 bait sets got as far as hearings
scheduled with minimal notice, before wildlife advocates
found out about it from a member of the Texas chapter of the
Sierra Club, who stumbled into the matter while attending a
meeting on other business where it was briefly discussed.
Energetic opposition organized at the last minute by
Wildlife Rehabilitation and Rescue, of Boerne, Texas, paid
off on December 16, 1994, when the EPA rejected the TDA
application. “The geographical area encompassed by the dis-
ease appears to be too large to ensure that the proposed con-
trol efforts could be managed and coordinated effectively,”
the EPA ruled. “The bait proposed for use could not be
expected to selectively target gray foxes, or the other six pur-
ported carrier species. And the proposed spacing of individ-
ual baits (one bait per acre) suggests that a large number of
non-target animals would take the baits and be killed. This
would create significant gaps in the proposed barrier treat-
ment that is intended to reduce the gray fox population and
confine the disease.”
Further, the EPA declared, “The proposed plan is
not likely to reduce the population of gray foxes significantly
enough to control the spread of rabies. Rabies only spreads
rapidly when the size of the carrier population becomes too
large. Many of the methods, e.g. traps and snares, used to
protect sheep and goats from predators such as coyotes may
actually help the gray fox,” because they “remove a carni-
vore competitor. This may only perpetuate a situation that
favors the gray fox population and the continued spread of
gray fox rabies.”
Endangered species
The EPA also noted that, “Since animals other than
those targeted may eat the baits, Compound 1080 could
adversely affect populations of [other] mammalian species of
special concern. Animals that are not currently considered to
be endangered could become so,” and eventually be listed for
protection under the Endangered Species Act. “These species
include swift foxes, black bears, Eastern spotted skunks,
Arizona blacktailed prairie dogs, and pocket gophers.”
The hint that predator poisoning could lead to ESA
involvement is especially meaningful to Texans, including
the administration of new governor Jeb Bush. Having inhibit-
ed development of the hill country between Austin and San
Antonio for nearly a decade, the ESA is so unpopular in
Texas that Bush actually campaigned on a pledge to seek a
statewide moratorium on ESA enforcement.
While the TDA application to use 1080 was denied,
the mere fact that it was filed serves notice that the predator
control establishment is again on the offensive––and is likely
to be strengthened by the election of a new Congress whose
leadership is closely supportive of western ranchers, hostile
toward the ESA, and inclined to return authority to state gov-
ernments. Public fear of rabies gives predator control advo-
cates an emotionally powerful argument, especially since two
humans have died of rabies in south Texas during 1994––one
before the TDA application was filed, and another, a 14-
year-old boy, in Edinburg on November 31.
Generally overlooked or discounted are stacks of
studies which have documented since 1909 that predator
killing does not lastingly depress either predator numbers or
predation itself. Indeed, the TDA application even disregard-
ed heavy evidence that increased pressure on fox and coyote
populations only produces faster reproduction. A 1972 study
done within the same region the TDA sought to seed with
1080 found that coyote litters actually increase from 4.3 pups
apiece when there is no trapping, to 6.9 pups apiece when
trapping is intensive. The difference comes about because
killing some predators makes more food available to the sur-
vivors, enabling them to carry and nurse larger litters.
Fox numbers down, not up
There is more recent evidence indicating that killing
foxes, coyotes, and the other alleged rabies-carrying species
stimulates population growth. According to the Texas Parks
and Wildlife Department, in an October 1, 1993 report pre-
pared in compliance with the Federal Aid in Wildlife
Restoration Act, the Texas grey fox population declined 39%
from 1990 through 1992. Skunks declined 24% and raccoons
12%. Coyote and bobcat populations were stable. Ringtails,
a scarce species, increased by 75%, but were still below their
population density of the preceding 15 years.
“Overall furbearer abundance decreased 18% from
1991 to 1992, and (also) 18% from 1990 to 1991,” wrote
principal investigator Sylvestre H. Sorola––who also noted
that the crash parallels the decline of trapping in Texas,
which sold an average of about 20,000 trapping licenses per
year throughout the 1980s but now sells under 6,000.
The TDA application acknowledged that oral vacci-
nation, used successively against fox rabies in Europe for 18
years, is probably “the best longterm approach for containing
the gray fox rabies disease,” but pointed out that the vaccine
is not yet approved for general use in the U.S., despite many
successful field trials. Final approval is believed to be near;
however, it is not yet designated for use with gray foxes.
Seemingly eager to discourage nonlethal rabies con-
trol, since it doesn’t kill predators, TDA Special Registration
Program coordinator Mark R. Trostle asserted in an October
14 response to questions raised by EPA Emergency Response
and Minor Use Section administrator Rebecca Cool that dis-
tributing the oral vaccine would cost $3.7 million a year,
without citing a complete cost estimate for the proposed 1080
program. In fact, 1080 and the oral rabies vaccinations are
distributed in an almost identical manner, embedded in bait
balls, which can be either air-dropped or hand-placed. Labor
and equipment costs would be the same. The most evident
difference would be that 1080 doses cost about 18 cents
apiece, whereas oral rabies vaccinations cost up to $2.00
each––and harm only the rabies virus.
Trostle’s October 14 document warned in conclu-
sion that the raccoon rabies outbreak spreading along the east
coast since the 1970s has occurred because, “Neither popula-
ion reduction nor a vaccination program of a magnitude [suf-
ficient] to halt the spread was instituted.” He implied that the
raccoon rabies pandemic had spread as far as Ohio due to a
lack of human intervention.
Killing wildlife doesn’t work
But as the Centers for Disease Control and
Prevention explained in an August 1993 communique, “The
current rabies epidemic has spread outward from West
Virginia since 1977, when hunters imported 3,500 raccoons
from Florida to restock the mountains. Some of the raccoons
were rabid.” The hunters were eventually caught and cited by
the U.S. Fish and Wildlife Service for moving the raccoons
without proper permits, but the damage had been done––and
was worsened by the response of the hunting and trapping
community, with the active encouragement of many state
wildlife agencies, which saw in rabies a means of promoting
trapping. Because raccoon pelt prices were at or near record
levels throughout the first decade of the pandemic, trappers in
West Virginia, Virginia, Delaware, Maryland, New Jersey,
and Pennsylvania accordingly killed more than 500,000 rac-
coons each and every year through 1987. Coonhunters proba-
bly killed as many more. Not surprisingly, the pandemic
moved north and east, in the direction of the most trapping
and hunting, through all five states.
As Dr. William Winkler of the National Centers for
Disease Control put it in the National Academy of Sciences’
handbook Control of Rabies: “Persistant trapping or poison-
ing campaigns as a means to rabies control should be abol-
ished. There is no evidence that these costly and politically
attractive programs reduce either wildlife reservoirs or rabies
Winkler’s conclusions, initially stated in 1973 and
reaffirmed in 1981, were affirmed again in almost the same
words by the National Association of State Public Health
Veterinarians, in their Compendium of Animal Rabies
Control, published in the Journal of the American Veterinary
Medical Association of January 15, 1994: “Continuous and
persistent government-funded programs for trapping or poi-
soning wildlife are not cost effective in reducing wildlife
rabies reservoirs on a statewide basis.”
Despite the EPA ruling against the TDA, the battle
against reinstatement of predator poisoning isn’t over. The
TDA still actively encourages ranchers and animal control
agencies to attack coyotes and foxes with M-44 spring traps,
which may be deployed without federal permission. Scented
with rotten meat and buried an inch or two deep, they are
designed to throw a sodium cyanide capsule directly into the
mouth of the animal who digs one up. The TDA also pro-
motes conventional predator trapping and shooting.
And 1080 baiting remains with us, too, albeit ille-
gally. U.S. Fish and Wildlife Service agents Rex Shaddox
and Doug McKenna just last year disclosed that government
officials were clandestinely selling unused supplies of 1080
left from before the 1972 ban took effect. Wrote Shaddox in
one memo to his superiors, “Right now, the [Wyoming]
State Agricultural Department and most all USDA [agents in
the area] are involved in the illegal poisoning with most
predator [control] boards in the state of Wyoming.”
According to the Summer 1994 edition of C o l o r a d o m a g a-
zine, “Over several years the two investigators compiled 120
reports with photographic evidence and 7,000 pages of infor-
mation transcribed from 344 tape and body-wire recordings.
One 85-page transcript specifically identifies a highly placed
supervisor in the U.S. Animal Damage Control Agency as
being personally involved with the selling of illegal poisons
for his own monetary gain. But when the sting went down,
no federal officials were ever charged, while six lesser con-
spirators were fined for only minor offenses. Despite much
tangible evidence of highly illegal poison sales, none of those
defendants served any time in prison.”
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