Our Stand

April 8, 2009
 
Katie Knoll
Public Involvement Unit Manager
Colorado Division of Wildlife
6060 Broadway
Denver CO 80216
 
                                    Transmitted by email
 
 
Dear Katie:
 
Pursuant to your letter of February 20, we understand that the Colorado Wildlife Commission intends to consider the issue of fertility control methods as a potential tool for managing overabundant and nuisance wildlife populations in areas where traditional methods are impractical or prohibited. 
 
In accordance with your request that the public submit comments on or before April 10, the Colorado Wildlife Federation has deliberated on the matter and crafted this letter.
 
In our view, fertility control methods are fraught with scientific and environmental ramification, many of which are fully understood. A full understanding of other ramifications has yet to be achieved. The following seven points represent our thinking and recommendations on fertility control policy.
 
First, a policy is necessary to ensure that the Division of Wildlife recognizes the emerging nature of ungulate fertility control, specifically, and the use of fertility control in wildlife populations, generally. In addition, we believe that the Division must maintain substantial, if not exclusive, control over its use to manage wildlife populations.  
 
Second, the Commission must stipulate unequivocally that fertility control shall be used only in cases where a current population level or distribution and a desired objective are both quantified and justified with data.
 
Third, the issue of monitoring the effects of fertility control applications must be addressed. Possibly, some type of bonding should be required. 
 
Fourth, proponents should be required to provide clear and convincing evidence that no methods of direct removal are legal, feasible and effective. 
 
Fifth, the policy should require that the application of fertility control is specific as to the number of species, gender, location and duration. CWF does not support any “broadcast” applications such as baits. 
 
Sixth, the matter of who will bear the expense must be clear within the policy. Normally, we expect that the proponent would bear the cost. 
 
Finally, the use of fertility control and the method must be communicated very clearly to the public and to sportsmen to minimize confusion.
 
Thank you for the opportunity to provide Colorado Wildlife Federation’s recommendations on this important policy matter.
 
 
Sincerely,                                                        
                                                                
John Smeltzer, Board Chair                                          Suzanne O’Neill, Executive Director
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