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WASHINGTON, Aug. 9 -- Project Coyote, Larkspur, California, has issued a public comment to the U.S. Department of the Interior. The comment was written on Aug. 1, 2022, and posted on Aug. 2, 2022.
The comment was on Docket No. DOI-2022-0008-0001.
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On behalf of Project Coyote's Science Advisory Board and the undersigned scientists, we would like to submit the below recommendations based on the best available scientific and academic research. Generally, we highlight the need for closer integration between Office of Law Enforcement (OLE) and U.S.Fish and Wildlife Service (USFWS) staff engaged in recovery of listed species. This would improve DOI programs for such species as well as ecologically sound management of public lands. Staff integration can aid in detecting and preventing illegal take. It can improve enforcement by, for example, coordinating monitoring of animals and patrolling of their habitat, and improving data-collection and investigations that should inform both interventions and iterative conservation planning.
A. Recommendations for USFWS and OLE regarding listed species and public lands:
Target law enforcement using predictive tools of modern criminal law enforcement: To improve protections for listed species that are under threat now, OLE and USFWS coordination should focus on poaching patrols and enforcement on public lands based on locations, timing, and perpetrators of past illegal activities (Treves et al. 2017).
Collaborate with public land groups that support the Endangered Species Act (ESA) and protective, ecologically based policies (see also following section): DOI should identify pro-protection groups to engage as volunteers for monitoring and vigilance. Closer collaboration with non-governmental organizations and local actors who are authentically pro-ESA and pro-protection rather than the traditional pro-hunting and pro-angling groups will contribute to mitigating illegal uses by increasing human presence in a listed species range, especially at times when USFWS staff are not in the field. Even if data are not perfect, the added human presence in the field can protect against poaching (Santiago-Avila et al. 2020; Santiago-Avila et al. 2022a).
Simultaneously, there is also...