Sinks Canyon WILD Comments Concerning the Proposed Amendment to Chapter 66 of the Wyoming Bighorn/Domestic Sheep Plan
Sinks Canyon WILD (SCW) is a non-profit organization created to advocate for Sinks Canyon's important natural and cultural resources and its surrounding environs. As such, our organization supports the judicious management of wildlife habitats and conditions that foster healthy native wildlife populations, including bighorn sheep.
We strongly object to the proposed amendment to Chapter 66 of the Wyoming Bighorn/Domestic Sheep Plan being adopted. If the amendment is adopted, it would guarantee that domestic sheep operators would not be held responsible for their actions that are injurious to the public’s wildlife. The broad language in this amendment effectively “holds harmless” domestic sheep operators from injuring wildlife populations at the expense of Wyoming taxpayers. Such a negligent proposal disregards the Wyoming Game & Fish Department’s (GFD) authority to wisely manage wildlife resources on behalf of the public good, making the amendment blatantly irresponsible. Adoption of this ambiguous amendment could quite easily lead to lawsuits not easily resolved.
Under the “Wyoming Plan,” the state livestock organizations are granted veto power over GFD’s wildlife management practices they find objectionable. The proposed amendment, along with the entire WYOMING BIGHORN/DOMESTIC SHEEP PLAN RULES (“Wyoming Plan”), therefore, plainly makes manifest the unlawful annulment of GFD authority granted by regulatory statute. The” Wyoming Plan” unquestionably undermines the GFD’s ability to wisely manage bighorn sheep on behalf of the public. The “Wyoming Plan” is, therefore, transparently unlawful, necessitating its repeal from state law.
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We are also distressingly aware of GFD’s alarming policy of “removing” (killing) wandering bighorn sheep if there is even the slightest possibility they have come in contact with domestic sheep. There have been at least two instances of multiple bighorns being killed by GFD in and near Sinks Canyon during the last three years.
As a conservation organization focused on the Sinks Canyon area, we oppose the current management policies and protocols that call for the immediate “removal” of wandering bighorn sheep suspected of, but not proven to be, infected by lethal respiratory diseases. During our conversations with local GFD personnel, we have heard the justifications for these actions, but believe that a more thorough examination of the assumptions and possible alternatives related to such management actions are needed to assure the public that wild populations of bighorn sheep are managed in a way that best ensures their long-term survival in the southern Wind River mountains.
It should be noted that bighorn sheep are identified in the Wyoming Game and Fish Department State Wildlife Plan – 2017 as a “Species of Greatest Conservation Need” and, therefore, a species to be afforded special attention in ensuring their survival. The U.S. Fish & Wildlife Service has also recognized bighorn sheep as a “species of concern.”
Specifically, SCW questions the following management policies and actions of removal of wandering bighorns simply on the suspicion that they may have a respiratory disease that could infect other healthy ones. This is counter to the Western Association of Fish and Wildlife Agencies publication “Conservation Challenges and Management Strategies in the 21st Century” and the management practices in other States and Canadian Provinces hosting bighorn sheep. At a minimum, bighorns should be tested and/or actually exhibit acute respiratory disease symptoms before removal. The current GFD policy effectively eliminates the possibility of herds reestablishing themselves in former habitats throughout the southern Wind River Mountains and many other localities throughout the State. SCW, therefore, plans to hold a public forum addressing the issues mentioned above and to provide available scientifically sound alternatives to the policy of killing all bighorn sheep attempting to recolonize their former habitat.
Thank you for the opportunity to make our comments and objections heard. Our organization hopes to foster further productive dialogue with the GFD concerning issues relating to the wise management of bighorn sheep and other native wildlife in the Sinks Canyon area.
Sincerely,
Ronald K. Smith, President
cc: Wyoming Game & Fish Commission
Wyoming Game & Fish Department Director