Audit of the U.S.D.A. Animal Damage Control Program

by Randal O'Toole
The Thoreau Institute

Table of Contents

  1. Executive Summary
  2. Introducing ADC
  3. Methods for Reviewing ADC
  4. ADC's Budget
    1. Overall Budget
    2. Distribution of Funding
      1. Overhead
      2. Congressional Earmarking
      3. The Western Region
  5. ADC's On-the-Ground Activities
    1. Areas of Work
    2. ADC's Effectiveness
    3. Reported Losses
    4. Protecting Livestock
    5. State-by-State Comparison
      1. Overall ADC Budgets
      2. ADC Livestock Protection Budgets
      3. Value of Reported Losses
      4. Reported Cattle and Sheep Losses to Coyotes
      5. Coyote Take and Harvest
      6. Cattle and Sheep Losses
        1. Cattle and Calves
        2. Sheep and Lambs
        3. NASS Estimates vs. ADC Reports
      7. Value of Herds and Losses
  6. Analyzing the ADC Program
    1. The Constitutionality of Animal Damage Control
    2. The Economic Justification for ADC
    3. The Politics of Animal Damage Control
    4. The Kansas Alternative
  7. Conclusions
  8. References

List of Tables

List of Figures

Executive Summary

The Animal Damage Control (ADC) program is administered by the U.S. Department of Agriculture under its Animal and Plant Health Inspection Service (APHIS). One of ADC's biggest and most controversial activities is killing coyotes and other predators, primarily to protect western livestock.

Two wildlife groups, Wildlife Damage Review, from Tucson, Arizona, and the Predator Project, from Bozeman, Montana, asked the Thoreau Institute to audit ADC's program. This audit examines ADC's budget in general and focuses in particular on the funds it spends controlling coyotes and other livestock predators. The principle findings include:

The Thoreau Institute can find little legal or economic justification for continuing a federal animal damage control program. Few benefit from such a program and those who do ought to pay for the program themselves. In any case the federal government should not be involved in what are essentially state and local problems.

The only reason that the program continues is political: ADC is pork barrel. Although ADC's constituency is tiny--fewer than 30,000 ranchers enjoy most of the benefits of the livestock program--Congress finds it easier to maintain wasteful programs than to cut any of them, no matter how tiny the constituency.

Shutting down the ADC program would save federal taxpayers $36 million each year. While this would increase costs to the people who benefit from the program, the increases would merely transfer costs from taxpayers who receive negligible benefits to those who ought to be paying for it. Moreover, most of the program's beneficiaries would spend less, do different things, and often do less environmentally harmful things, than ADC is doing today.

While ADC represents a tiny portion of the federal budget, programs like ADC do enormous fiscal and environmental damage. Congress should immediately terminate federal funding to ADC and similar programs, letting them live or die based on state or local resources.

Introducing ADC

The USDA's Animal Damage Control program says that its mission is "to provide leadership in wildlife damage control to protect agricultural, industrial, and natural resources and to safeguard public health and safety."[1] This mission, however, didn't spring up overnight, nor was it set by Congress in any particular legislation.

ADC traces its history to an 1885 USDA survey asking farmers about crop damage by birds. In 1896, when USDA's Division of Biological Survey was created, one of its missions was "to educate farmers about birds and mammals . . . so that the destruction of useful species might be prevented." In other words, USDA's goal was to protect wildlife, not to destroy it.

Under the U.S. Constitution, wildlife are owned by the states, and control of wildlife would be a matter between the states and private individuals. But the designation of large federal reserves, particularly the national forests which were actively used by ranchers for livestock grazing, got the federal government involved.

In 1905, after the national forests were transferred from the Department of Interior to the Department of Agriculture, the new Forest Service began working with the Biological Survey to find ways to control wolves and coyotes. The Forest Service was beginning to charge fees for livestock grazing on national forests, and ranchers objected to paying fees when their cattle and sheep were killed by wildlife.

In 1914, under pressure from ranchers, Congress appropriated the first funds dedicated to "experiments and demonstrations of predator control." These appropriations expanded during World War I in an effort to increase meat production.

After the war, USDA started an "Eradication Methods Laboratory" in Albuquerque, New Mexico. This was moved to Denver in 1921 and, after several name changes, became known as the Denver Wildlife Research Center.

Predator control was controversial as early as 1930, when the American Society of Mammalogists stated its opposition to ADC. This, however, only led Congress to pass the Animal Damage Control Act of 1931, This law directed the Secretary of Agriculture to:

determine, demonstrate, and promulgate the best methods of eraadication, suppression, or bringing under control on national forests and other areas of public domain as well as on State, Territory or privately owned lands [predators] and other animals injurious to agriculture. . . ; and to conduct campaigns for the destruction or control of such animals.
The wording of this law makes it clear that a principle reason for it is the large expanses of federal land, including the national forests and public domain lands that would eventually be managed by the Bureau of Land Management. Even today, two-thirds of ADC's predator control money is spent on public lands.

The law's wording also makes clear that eradication was acceptable to most people, even if some scientists objected to it. The Biological Survey soon eradicated wolves from nearly every state in the Union. Coyotes, which multiplied much more rapidly than wolves, proved more difficult.

In 1939, President Roosevelt consolidated all federal wildlife programs, including the Biological Survey, in the Department of the Interior under the new Fish and Wildlife Service. This agency continued predator control campaigns with little controversy until the 1960s, when pesticides and toxic chemicals became an important issue.

In 1963, Secretary of the Interior Stewart Udall commissioned a Predator and Rodent Control Committee headed by Starker Leopold. The committee's 1964 report charged the ADC program with indiscriminate, nonselective, and excessive predator control. This led to a reduction in predator control practices, including leghold traps as well as poisons.

Controversy continued with publication in 1971 of a popular book titled Slaughter the Animals, Poison the Earth. The book, by well-known outdoor writer Jack Olsen, criticized predator control efforts in general and focused on the ADC program in detail.[2] Perhaps in response, Secretary of the Interior Walter Hickel appointed a new predator control committee that same year. The committee's 1972 report recommended restrictions on the use of poisons and favored teaching landowners how to control predators over direct control by federal agents. This led President Nixon to ban the use of poisons for predator control.

In 1975, President Ford amended Nixon's order to allow the use of sodium cyanide in a device called an M-44, which shoot the chemical into an animal's mouth when triggered by an animal eating a bait. The ADC program continued to kill predators with other methods as well, predominantly leghold traps and aerial shooting.

In 1979, Secretary of the Interior Cecil Andrus issued a new policy emphasizing nonlethal controls of predators. The policy also banned further research on 1080, a chemical that had been banned by Nixon's policy but that the Fish and Wildlife Service continued to study in the hope that the ban would be rescinded.

Andrus' policy was strongly opposed by ranchers, and the ranchers were supported by western senators and representatives who held pubic hearings hostile to the policy. As a result, in 1980 Congress asked the president to consider transferring ADC back to the Department of Agriculture.

The election of Ronald Reagan led to major policy changes. Soon after taking office Secretary of the Interior James Watt rescinded Andrus' policy and President Reagan revoked Nixon's executive order. Rather than transfer ADC to the Department of Agriculture, however, the leaders of Reagan's privatization initiatives wanted to take it out of the federal government altogether. This idea got no further than proposals to privatize the national forests.

In 1985, a letter from 20 senators asked Reagan to move ADC into the Department of Agriculture. The move was made through legislation in 1986, and ADC was made a part of the Animal and Plant Health Inspection Service. Congress followed this move with a major boost in ADC's budget. However, much of that increase went to projects other than protecting livestock.

One of ADC's responses to criticism has been to expand its original mission of protecting livestock from predators to include such things as protection of crops from blackbirds, roads and structures from beaver dams, airports and aircraft from geese, and endangered Aleutian Canada geese from Arctic foxes. While ADC highlights these activities in its reports to Congress and the public, most of the program's resources are still spent killing livestock predators.

ADC's federal funding is supplemented by operational funds from state and local governments as well as other entities such as stockgrowers associations. These funds are called "cooperative contributions" and totaled to nearly $17 million in 1992.

ADC's general procedure is supposed to be to wait until someone reports property or other damage by wildlife. Perhaps a sheep rancher finds lambs killed by coyotes. After verifying that wildlife were responsible for the damage, ADC determines the best way to address the problem.

This may be to try to scare away the wildlife--perhaps with guard dogs in the case of coyotes, or loud noises in the case of birds--relocate the wildlife, or to kill it. Wildlife may be killed by poison using M-44s; by shooting from the air or ground; by trapping; or a variety of other ways.

Environmentalists continue to criticize the ADC program for several reasons. Popular wisdom views animals in general and predators in particular differently today than in 1931. The idea of "eradicating" any species seems abhorrent. Where predators were once considered pests, they are now thought of as a natural and even essential part of the ecosystem.

Some ranchers, for example, now say that they can live with coyotes. In fact, since coyotes mostly eat rodents, not sheep, farmers say that leaving the coyotes alone helps reduce rodent problems on their land. Dayton Hyde, an Oregon rancher and author of Don Coyote--his story of living with coyotes on his land--worries that ADC efforts will kill coyotes that don't attack livestock, creating opportunities for coyotes that do eat livestock to move onto his land.[3]

In a more general sense, environmentalists fear that many of the predators killed by ADC are not the ones who might be guilty of eating livestock. When shooting coyotes from a helicopter or airplane, ADC employees have no way of knowing which ones kill lambs and which ones live exclusively on rodents. People find this lack of discrimination more objectionable today than they did 60 years ago. Leghold traps and M-44s are even less discriminating than guns, and people worry that poisons and traps may harm their own dogs or other pets.

An even more telling argument is that ADC's methods don't work very well. On the one hand, federal and state ADC programs succeeded in exterminating wolves, grizzly bears, and other predators from many states that might otherwise still have populations of such animals. On the other hand, livestock predation continues by the wily old coyote, and despite all the millions that ADC has spent, its own internal documents indicate that the problem is getting worse.

Even if the ADC program worked and it could do so without hurting non-target animals, people question why a federal program that benefits only a few is really necessary. Some 40 percent of ADC's operational budget, and presumably a similar share of its research budget, is spent protecting or studying ways to protect the livestock of the 27,000 ranchers who use public lands. This means that, in addition to below-cost grazing fees, a wool-growers subsidy, and other federal aide, these ranchers each get a $550 per year subsidy from ADC.

All of these problems will be addressed in this report. The next chapter describes the Thoreau Institute's methods for reviewing government agencies and programs like ADC. Following it are three major chapters reviewing ADC's budget and other pertinent data.

Chapter III looks at the ADC program's budget and especially the part of the budget dealing with protecting western livestock. All of the data in this report comes from the Department of Agriculture, much of it from a similar examination recently made by the Western Region of the ADC itself. The Thoreau Institute's conclusions will be compared with those made by the ADC.

Budgetary information in this report extends as far back as 1980. However, due to inflation 1980 dollars are not strictly comparable with 1994 dollars. Unless otherwise noted, all dollars cited are "nominal" dollars, meaning that they are not adjusted for inflation. When the phrases "1994 dollars" or "inflation-adjusted dollars" are used, all dollars prior to 1994 have been adjusted using gross national product price deflators to be equal to 1994 dollars.

Chapter IV examines ADC's on-the-ground activities. In large part this relies on ADC records reporting various types of animal damage and ADC's response. Several tables present state-by-state information, including data gathered by the National Agricultural Statistics Service on predation of sheep and cattle that is probably more reliable than ADC's records.

The report's final chapter discusses the legal, economic, and political aspects of the ADC program. This section includes some suggestions for opponents of ADC predator-killing efforts. The report concludes by summarizing the perverse incentives created by the ADC program that were identified by this study.

Methods for Reviewing ADC

The Thoreau Institute's economic analyses of government agencies does not follow the traditional procedures used by government economists and planners. While the latter focus on benefit-cost ratios, the Thoreau Institute focuses on the economic incentives faced by decision makers.

A traditional analysis estimates the benefits and costs of a program or alternative programs to calculate whether the benefits exceed the costs. If they do, the analyst recommends the alternative with the highest net benefits. If they do not, the analyst supposedly recommends against the programs.

This method naïvely assumes that Congress, agency employees, and the people served by the program want to have the benefits exceed the costs. In fact, the incentives faced by the various policy makers often lead them to use criteria that are very different from net benefits and to spend far beyond the point where benefits no longer exceed costs.

The Thoreau Institute's method uses benefit-cost analyses whenever possible, but the results of those analyses are taken as symptoms of potential problems with the system, not as guides for policy makers. Of course, a benefit-cost analysis is not always possible, but whether possible or not the more important step is to analyze the incentives faced by various participants in the system.

The people who benefit from a program, for example, care little about the program's net benefits. Instead, they care about the benefits that they receive vs. the costs they incur. If their benefits exceed their costs, they are likely to support the program even if the costs to society are far greater than the public benefits.

The supporters of a federal program soon learn that they have to express their support before Congress. The incentive of most members of Congress is simple: to get re-elected. An important way to achieve this goal is to try to please all of the various interests who walk in their doors--especially those who vote as a block or make campaign contributions.

It seems difficult to imagine that an interest group as small and diffuse as a few thousand western livestock ranchers who are spread out over many states can have a major influence on Congress. Yet they do because of a Congressional tactic known as logrolling.

In a narrow sense, logrolling takes place when a senator or representative votes for a project supported by another senator or representative in order to gain the vote of the second congressman for a project supported by the first. In this sense, ranchers only have to gain the support of a few key members of Congress, especially if one of those members is on the Senate or House Appropriations Committee.

In a broader sense, Congress gets its voters to log-roll by giving them all a little something. Urban residents who might not favor aerial hunting of coyotes, for example, may tend to vote for senators who support such hunting because the senators also supported urban projects such as hospitals, highways, or mass transit systems.

The people who run the programs feel only a little differently. Despite their lofty missions, the underlying goal of any bureaucracy is to maximize its budget. Managers thus respond to the goals of the people funding the program, which are often very different from maximum net benefits. If Congress--or a few powerful members of Congress--wants to kill coyotes, then some bureaucracy will respond to that desire in order to get more funds.

Together, the legislators, bureaucrats, and special interests that benefit from a program form an "Iron Triangle" that is difficult to break. Each leg of the triangle has a different goal, but they can all achieve their goals in the same way: by spending tax-dollars or deficit-dollars on programs that benefit the special interests.

It is the nature of such programs to be highly wasteful. If the program could make money for the special interest, they would probably do it themselves rather than ask taxpayers to fund it. Unlike private businesses, whose spending is limited by their income, bureaucracies have no natural check on their spending. The overall spending of most state legislatures is constitutionally limited to their income, but Congress does not have such a limit.

The Thoreau Institute's methods, then, focus on identifying key members of a program's Iron Triangle, following the money to see how it reinforces that Triangle, and determining whether and how the program fails to live up to its original goals. The first step in this procedure is to examine the program's budget.

ADC's Budget

Depending on which range of years are examined, ADC's budget has grown tremendously--over the past ten years--or has barely changed--over the past fifteen years. This section looks at how much money the ADC spends, where it comes from, and where it goes.

The report takes a special look at the Western Region, both because it spends most of ADC's operational money and because it was the subject a recent major review within ADC itself. In this it relies heavily on data in a "Program Evaluation Panel Report," or PEP report, prepared by ADC in 1993.

Overall Budget

The animal damage control program forms just two line items in the annual budget that the Animal and Plant Health Inspection Service (APHIS) presents to Congress. These are "ADC operations" and "animal control methods development." For short, they will be referred to here as "operations" and "research."

Figure one tracks the operations and research budgets since 1980. As shown, operations suffered a major cut in 1982, apparently as a part of President Reagan's attempts to control domestic spending. But funding was restored in 1985 and increased by another 40 percent in 1986. Research funding received an 80 percent boost the following year.

These increases in funding coincide with the transfer of ADC from the USDI Fish and Wildlife Service to the USDA Animal and Plant Health Inspection Service. This transfer was made because certain members of Congress were unhappy with the Fish and Wildlife Service's handling of ADC and felt that the program would better meet their goals if managed under USDA. The funding boost is apparently related to those goals.

Figure one: ADC's federal funding has trended upward since 1980, with the largest boost in 1986 when the program was transferred from USDI to USDA. Source: USDA and USDI budget documents presented to Congress for the relevant years.

Aside from the 1986 boost, ADC funding shows an apparent upward trend. This is deceptive, however, because figure one does not account for the effects of inflation. Figure two, which is adjusted to 1994 dollars using gross national product price deflators, suggests that today's ADC funding is only slightly greater than it was in 1980--but still much more than in 1983.

Figure two: After adjusting for inflation, the 1986 boost is apparent but the upward trend is less so. Source: Same as figure one adjusted using gross national product price deflators calculated by the Department of Commerce.

Distribution of Funding

The fact that ADC budgets have not significantly increased, relative to inflation, raises concerns among western ranchers because Congress has diverted an increasing amount of ADC funds to non-livestock programs. This can be seen by tracking ADC's spending.

Within APHIS, ADC budgets are tracked in much greater detail than the two line items presented to Congress. In particular, the operations budgets are divided into four broad line items: "agency support," "program support," "program investments," and "program delivery." The latter item is where the on-the-ground work takes place, and it is divided into eight resources: "aquaculture," "livestock," "forest/range," "crops," "human health and safety," "property," and "wildlife."


Agency support, program support, and program investments can all be considered "overhead" to the on-the-ground activities. This overhead amounts to about 20 percent of the program's total budget (figure three). Agency support includes spending by APHIS on such things as budgeting, public affairs, planning, and personnel. Program support includes funds spent by ADC's staff in Washington, DC, and on its administrative staff in the western and eastern regional offices.

Figure three: Though declining slightly in relative importance, the Western Region still receives the lions share of ADC funds.

Program investments includes funds spent on the programmatic environmental impact statement (EIS) and the management information (MIS). It also includes contracts to other agencies such as to the National Agricultural Statistics Service to gather data on livestock losses and to Utah State University to develop an academic program for animal damage control. It also covers the costs of operating a supply depot in Pocotello, Idaho. Table one shows that ADC spent over $7.5 million on these programs between 1987 and 1994.

Table One
ADC Program Investments, 1987-1994

             	Nominal Dollars	1994 Dollars
EIS (1)      	$2,686,532	$3,057,760
MIS (2)      	 2,567,510	 2,737,049
Pocotello (3)	   513,058	   541,973
NASS (4)     	   600,000	   632,798
USU (5)      	 1,053,680	 1,103,140
Other (6)    	   160,808	   162,977
Total        	$7,581,588	$8,235,697

1.  Programmatic EIS
2.  Management information system
3.  Supply depot
4.  National Agricultural Statistics Service contract studies
5.  Development of academic program at Utah State
6.  Funds to various universities.
Source: ADC Western Region PEP Report.

ADC divides program delivery into its western and eastern regions and research, which is done at the Denver Wildlife Research Center. With about 54 percent of the program delivery budget, the Western Region is the largest, but its share has declined from 62 percent in 1985. The Eastern Region's share has increased from 13 percent to 16 percent, while research has increased from 25 percent to 30 percent.

Congressional Earmarking

As ADC's budget has increased in nominal dollars, Congress has increasingly directed chunks of it to specific activities. Such Congressional directives, or "earmarks," increased from less than $1.2 million in 1985 to well over $10 million in 1993.

Some of this earmarking is for programmatic-type activities such as the EIS and the Utah State academic program. But most is for specific, on-the-ground actions. For example, between 1987 and 1994, Congress directed that over $2.1 million be spent protecting North Dakota sunflowers from blackbirds, that over $1.7 million be spent on a guard dog program for Northwest and Minnesota farmers, and that nearly $1 million be spent protecting Texas citrus crops from grackles.

Table Two
Congressional Earmarking, 1987-1994
(thousands of nominal dollars)

Location    	Activity        	1987	1988	1989	1990	1991	1992	1993	1994
Program     	EIS             	500	500	500	500	500	500		
Utah        	USU curriculum  				250	250	250		
Texas       	Grackles/citrus 	300	300	300					
N. Dakota   	Blackbirds      			368	368	468	568	568	468
Montana     	Expand ADC      		100	100	100	100	100		
Nevada      	Pilots          								100
New Mex.    	Sandhill crane  								60
Northwest   	Guard dogs      		155	205	205	205	205	205	205
West        	Predator control			500	500	500	500		
West        	Equipment       			260	260	260	260		
Minnesota   	Guard dogs      	45	45	45	45	45	45	45	45
Minnesota   	Wolves          						250	250	250
Wisconsin   	Beaver          		100	100	100	100	100	100	100
Arkansas    	Blackbirds      								50
Illinois    	Blackbirds      								50
Vermont     	Squirrels/maple 		40	52	52	52	52		
Louisiana   	Fully fund      				100	100	100		
Louisiana   	Rice            								120
Arkansas    	Restore funding 			207	240	240	240	240	240
Maine       	FandW           				75	75	75	75	75
Mississippi 	Operations      				100	100	100	100	100
Mississippi 	Beaver          					100	100	100	100
Alabama     	Increase program					100	100	100	100
Delta states	Operations      		125	125	125	125	125	125	125
East        	Equipment       			125	125	125	125		
Hawaii      	Rats            	240	240	240	240	240	240		240
AZ, CA, NV  	Lithium chloride	100	100	100	100				
Delta States	Blackbirds      		100	150	150	150	150	150	150
N. Dakota   	Blackbirds      			200	300	300	300		
Louisiana   	Rice            								30
Northwest   	Seedlings       		100	100	100	100	100		
Northeast   	Seedlings       		150	150	150	150			
DWRC        	Maintenance     		317	317	317	317	317		
DWRC        	Equipment       		489	489	489	489	489		
DWRC        	Construction    					5,000			
DWRC        	Pesticides      				1,500	1,500	1,500		
DWRC        	Non-lethal      					500	750	8,300	4,259
TOTAL       	                	1,185	2,861	4,633	6,491	12,191	7,641	10,358	6,867
Before making adjustments for inflation, Congress has specified where more than $52 million of ADC's budget must be spent over the past eight years. Much of this money has been directed to a few specific states, often by representatives of those states on the Senate and House appropriations committees. "DWRC" stands for the Denver Wildlife Research Center. In 1993 and 1994, Congress directed that at least half the funds spent at this center be devoted to non-lethal activities. Source: Western Region PEP report through 1992 and ADC budgets for 1993 and 1994.

In ADCs Eastern Region, money has been earmarked for, among other things, protecting Wisconsin farmers from beavers ($0.7 million) and Vermont maple syrup from squirrels ($0.25 million). Even more money has been earmarked for research on such things as protecting Hawaiian sugar cane and macadamia nuts from rats ($1.7 million), Northwest tree seedlings from mountain beaver ($0.5 million), and developing a North Dakota sunflower that can resist blackbirds ($1.1 million).

Increases in the research budget kept up with earmarking, but not in the operations budget. Between 1987 and 1992, ADC's operations budget nominally increased by $3 million. But after inflation, the operations budget declined by more than $1 million, so the $3 million increase in earmarking ate into other activities. While formal earmarking declined in 1994, ADC maintains budgets in most of the states to which they had been formerly directed so as to maintain good relations with Congress.

The Western Region

ADC's Western Region includes sixteen offices covering seventeen western states plus Alaska and Hawaii. Alaska and Hawaii are managed out of the Washington state office, while activities in Kansas are nominally managed out of the Nebraska state office.

Although the Western Region covers a full range of ADC activities, about three-fourths of its federal funds are spent protecting livestock. Every state program except Washington, Alaska, Hawaii, and North Dakota spends over half its federal funds on livestock protection. States in the arid West--Idaho, Montana, Wyoming, Nevada, Utah, Colorado, Arizona, and New Mexico--all spend over 80 percent of their federal funds on livestock protection (figure four).

Since the Western Region's budget is nearly three-and-one-half times larger than that of the Eastern Region, western livestock protection is the dominant service provided by ADC operations. This activity consumed 53 percent of ADC's total on-the-ground operations in 1992. However, this is down from 67 percent in 1985.

Overhead--agency support, program support, and program investments--adds nearly 25 percent to ADC's on-the-ground expenses. When this is counted, the program spent a total of $13.3 million on western livestock protection in 1992.

Figure four: The ADC programs in most western states devote most of their resources to livestock protection. In the arid, intermountain states, more than 80 percent of ADC's efforts go to livestock protection. Source: ADC Western Region PEP Report.

Most state or local government provide cooperative funding to ADC's programs. As a whole, cooperative funding for livestock protection nearly matches the federal funds, but ranges from less than half of the federal funds in four states to nearly twice the federal funds in South Dakota and Texas (figure five).

Figure five: On this chart, 100 percent means that state and local funding exactly match federal funding. While this is ADC's goal, most states fall far short and it is met only because of the significant contributions of Texas and California. Source: ADC Western Region PEP Report.

The amounts shown in figure five are averages for the eight-year period between 1985 and 1992. Cooperative contributions by most states stayed fairly constant relative to federal funding over this period, but fluctuated considerably in Arizona and Nebraska. In Arizona, for example, cooperative contributions ranged anywhere from 10 to 36 percent of the total.

Inflation combined with Congressional earmarking reduced the federal share of livestock protection funding by about 10 percent between 1985 and 1992 (figure six). Federal funding reached a low of 84 percent of the 1985 levels in 1990, and has recovered somewhat since then. State funding has fluctuated but in the long run has kept up with inflation.

Figure six: After adjusting for inflation, federal funds for western livestock protection declined steadily between 1985 and 1990. While this has turned around somewhat, funding still falls short of 1985 levels. Source: ADC Western Region PEP Report.

A disproportionate share of livestock protection funds are spent on public lands (figure seven). About half of the eleven Western states, but a much smaller percentage of the six border states, are publicly owned, mostly national forests and BLM lands. About half of the national forests are closed to ADC work pending preparation of NEPA documents, and most BLM lands are similarly closed to all but "emergency" work. Yet an average of three-fourths of all federal livestock funds, and three-fifths of cooperative funds, are spent on public lands.

Figure seven: The vast majority of western ADC livestock funds are spent on public lands. This gives public land ranchers an additional incentive to overgraze. Source: ADC Western Region PEP Report.

ADC's On-the-Ground Activities

Each year, ADC compiles information about its activities in a report consisting of about a dozen tables of data. These tables include state-by-state information about where money is spent, where it comes from, how much animal damage is reported to it, and how many animals it kills or captures in response. This section contains a detailed review of certain of these tables.

Areas of Work

ADC divides its work into four major categories: protection of agriculture, human health and safety, property, and natural resources. Agricultural work is further subdivided into aquaculture, livestock, forest/range, and crops. Human health and safety is primarily protection of aircraft and airports from birds, but may also protect human health from such threats as alligators, bears, and bats.

Natural resources is primarily protection of some forms of wildlife, such as rare or endangered species, against other forms. This may also include forest protection, even though most forestry work is classified as agriculture. Property includes a wide variety of activities, such as protecting dikes from beaver, buildings from rats, and clothes from mice.

Table three compares the Western Region budgets for each of these areas for 1987 and 1992. Nominally, all have increased. But after adjusting for inflation, the crop program declined while the livestock program remained constant. The other programs have grown by large amounts.

Table Three
1987 and 1992 Western Region ADC Expenditures
(thousands of dollars)

                	1987	in 92$	% Fed	1992	% Fed	% change
Aquaculture     	0	0	--	176	91	--
Livestock       	17,179	20,760	52	20,829	51	0
Forest and range	748	904	44	1,483	42	64
Crops           	2,248	2,717	63	2,342	65	-14
Human health    	619	748	45	1,109	42	48
Property        	864	1,045	24	2,030	39	94
Wildlife        	393	475	43	877	42	85
Total           	22,051	26,649	51	28,846	50	8
ADC still spends most of its money on livestock, but the livestock budget has remained constant while other budgets have increased. The second column of numbers shows the 1987 budget adjusted for inflation to 1992 dollars. The "% Fed" columns show the percentage of funds paid by the federal government; the remainder are paid by local cooperators. The "% change" column shows the increase or decrease in real dollars between 1987 and 1992. Source: Western Region PEP report.

These budgetary trends may reflect the changing environment for the ADC program. Urban America no longer thinks that carnivores like coyotes and wolves are evil and should be exterminated. Instead, these animals are considered as cuddly as the family dog--in fact, owning a dog with wolf lines is the latest fad.

This new attitude threatens ADC's main mission. But no bureaucracy dies when the need for its mission disappears. Instead, it finds a new mission that reflects a new constituency. So the ADC is moving into areas that will appeal to urbanites such as protecting endangered species from predators, protecting airplanes from seagulls, and protecting catfish farms from cormorants.

Table three also shows the percentage of each activity that is funded by the federal government. ADC's goal is to have state and local cooperators fund half its budget--then it can tell Congress that federal funding will be matched with local funds. While it meets this goal overall, the variation is wide--from less than 10 percent for aquaculture to over 60 percent for property.

Table four shows the various sources of funds for livestock protection. After the federal government, most funding is provided by states, counties, and organizations such as stockgrowers' associations. "Revolving funds" are found only in a few states--Oklahoma, South Dakota, and Utah--so are probably local in origin. Other federal agencies such as the Forest Service also provide a small amount of cooperative funding.

Table Four
Source of Funds for Livestock Protection in 1992

Source             	Amount      	Percent
Individual         	    $12,049	  0
Organization       	  2,164,309	 10
County             	  3,050,690	 14
State              	  4,592,967	 22
Fur sales          	     46,327	  0
Revolving funds    	    229,368	  1
Federal cooperators	    191,036	  1
ADC                	 11,031,676	 52
Total              	$21,318,422	100
States, counties, and organizations provide most of the matching funds for ADC's livestock budgets. Source: ADC 1992 report, table 1a.

Again, while the overall livestock program meets the goal of being about half funded by state and local entities, matching funds vary widely among states. As will be shown below, federal funding for livestock protection in individual states can vary from 11 percent to 100 percent.

ADC's Effectiveness

The western sheep industry reports increased losses to predators and has accused ADC of falling down on its job of protecting livestock. In response, the Western Region prepared a report, known as the "Program Evaluation Panel" or "PEP" report, that agrees with many of the industry's accusations.

The PEP report concludes that "In general, ADC effectiveness in protecting livestock has decreased since 1985." Livestock losses are increasing, says the report, despite the fact that ADC is killing a third more coyotes now than in 1985.

The report gives several reasons for this alleged reduction in effectiveness. First is the difficulty of complying with the National Environmental Policy Act. This is not so much the programmatic EIS but local environmental assessments (EAs) required by the Forest Service and BLM. Until such EAs are done, the Forest Service won't allow any ADC activities on a national forest and the BLM will allow only "emergency" activities.

Only about half of the national forests in the West have EAs for ADC, and few BLM districts do. In the meantime, ADC state offices have diverted resources away from fieldwork to helping prepare the EAs. This cost the ADC an estimated $400,000 in 1992 and presumably similar amounts in other recent years.

When the EAs are done, the final decisions often restrict the type of control activities that the ADC can do. Local officials blame other agencies' NEPA processes for "work stoppage, restriction of using certain tools/methods, increase in confirmed and reported losses, reduced aerial hunting time, loss of cooperative support, and private control by some permittees."[4]

In addition to NEPA, the PEP report cites the Endangered Species Act, Federal Insecticide, Fungicide, and Rodenticide Act, and Migratory Bird Treaty Act as laws that "are restricting the ability of ADC to effectively discharge its responsibility within the current funding levels."

The report also blames lack of funding for ADC's reduced effectiveness. Funding for livestock protection has not kept up with other programs or with inflation. The report points the finger at Congressional earmarking but does not openly complain about the earmarking process.

The PEP report also notes that private trapping of coyotes for their furs has dramatically declined, mainly because fur prices have fallen by two-thirds. As recently as 1980, over 300,000 coyotes were taken by private trappers in the West. At that time, pelts sold for about $30 each. By 1989-90, prices had fallen to under $10 and only 27,000 were trapped.

This suggests that, if killing coyotes is truly a sound goal, ADC could do it much less expensively by paying a bounty on coyote pelts. If ADC spends an average of $100 to kill a single coyote, but private trappers will trap 100,000 more coyotes with a $20 increase in fur prices, then increasing fur prices would be far more efficient. A major problem with this, of course, is that private trappers are probably even less selective than ADC about targeting problem animals.

The PEP report speculates that, since ADC's resources for livestock protection are declining, but the numbers of coyotes taken is increasing, coyote populations must be increasing. While this is one possible explanation, the report admits that others are also possible.

One major flaw with the PEP report is that it offers no evidence that livestock predation by coyotes is actually increasing. The report cites "verified losses" but not actual or reported losses. As the ADC frequently emphasizes, verified losses are only a fraction of the total and are certainly not a statistically sound measure of changes in losses over time.

The PEP report concludes that ADC needs more funding for field operations to hasten compliance with NEPA and meet the challenge of increased coyote populations. More research funds are also needed, says the report, to develop new methods of control to replace older methods that have been restricted by law or local rules. Without additional funding, predicts the report, "the ineffectiveness of ADC services will accelerate even more rapidly."

Data gathered by ADC since the PEP report was written contradicts many of the report's conclusions. For one thing, coyote fur harvests have considerably increased since 1990, the last year listed in the PEP report. According to ADC records, western coyote fur harvests reached nearly 120,000 in 1992.

Even more important, ADC reports indicate that predation by coyotes significantly decreased in 1992. These reports are accumulated by the ADC in May and probably were not available to the authors of the PEP report (which was published in June of 1993). As shown in table seven below, the reported value of livestock killed by coyotes declined by two-thirds, and the value of sheep reported killed by coyotes declined by 49 percent from 1991 to 1992.

ADC records of reported losses are no more accurate than its records of verified losses. But they are the only data available in a time series. These data suggest that the livestock losses to predators may have little to do with the "effectiveness" of the ADC program.

Reported Losses

ADC keeps extensive records of losses to wildlife of crops, animals, property, and so forth that are reported to it each year. Table five shows that, between 1990 and 1992, ADC recorded over $128 million worth of damage of various sorts.

In the table, "records" are the number of types of damage, such as coyotes killing lambs. All coyote-killed lambs in a given state would be included in one record. "Units" are number of incidents, such as the number of lambs killed by coyotes. But units can also be acres of crops damaged by birds, airplanes damaged by seagulls, or buildings damaged by beavers.

Table Five
ADC Damage Reports

Year 	Records	Units	        Value
1990 	 2,762	1,830,592	 $50,087,037
1991 	 3,522	1,214,456	  47,388,555
1992 	 5,776	  215,182	  30,944,414
Total	12,060	3,260,230	$128,420,006
ADC's damage reports have been increasing in number but declining in value over the last three years. "Records" indicates the number of different types of reports, such as coyote's killing sheep in a given state. "Units" indicates the number of acres, incidents, animals, or plants damaged. "Value" is the value of the damaged resource. Source: ADC 1992 report, table 4a.

Some idea of ADC's records can be gained from table six, which lists all individual records for 1990 through 1992 for which the damage was estimated to be greater than $500,000. These range from single "incidents" between a hawk or Canada goose and an aircraft which cost over $2 million each to damage of over 230,000 acres of sunflowers by blackbirds which, cumulatively, also cost some $2 million.

Table Six
Top ADC Damage Reports for 1990 through 1992

State	Year	Resource Damaged	Responsible Species	Number	Units	Value
AR	1990	Rice              	Blackbirds      	12,200	Acre    	$6,100,000
CA	1990	Standing trees    	Black bears     	52,200	Each    	3,445,200
MS	1990	Catfish           	Cormorants      			3,300,000
OH	1991	Corn              	Blackbirds      	1	Incident	2,869,000
OH	1991	Corn              	Multiple species	1	Incident	2,761,000
WA	1990	Airport/aircraft  	Canada geese    	1	Incident	2,500,000
TN	1991	Non-res. buildings	Starlings       	1	Incident	2,500,000
ND	1991	Sunflowers        	Blackbirds      	800	Incident	2,446,865
ND	1990	Sunflowers        	Blackbirds      	231,405	Acre    	2,005,585
WA	1991	Standing trees    	Porcupines      	1	Incident	2,000,000
MA	1992	Safety, aviation  	Hawks            	1	Incident	2,000,000
OR	1992	Standing trees    	Black bears      	24	Incident	1,971,700
ND	1992	Sunflowers        	Blackbirds      	523	Incident	1,543,985
HI	1992	Safety, aviation  	Barn owls       	15	Incident	1,505,721
WI	1991	Non-res. buildings	Ring-billed gulls	5	Incident	1,501,500
TX	1990	Cattle, calves    	Coyotes          	3,376	Each    	1,442,996
TX	1991	Pasture           	Prairie-dogs     	18,053	Acre    	1,319,810
TX	1991	Cattle, calves    	Coyotes          	3,021	Each    	1,240,835
NM	1990	Rangeland         	Rats, Kangaroo   	16	Incident	1,061,500
NM	1991	Cattle, calves    	Coyotes          	2,485	Each    	1,050,526
AR	1992	Rice              	Blackbirds      	66	Incident	990,000
AR	1991	Rice              	Blackbirds      	56	Incident	840,000
CA	1991	Cattle, calves    	Coyotes         	2,398	Each    	837,546
TX	1990	Sheep, lambs      	Coyotes          	14,135	Each    	834,141
NM	1990	Pinto beans       	Prairie Dogs     	2	Incident	827,172
AZ	1990	Cattle, adults    	Blackbirds      	1,601	Each    	818,700
GA	1991	Other trans. safety	White-tailed deer		Incident	758,000
WA	1992	Standing trees    	Black bears      	2	Incident	660,000
TX	1991	Sheep, lambs      	Coyotes          	12,363	Each    	625,790
NC	1991	Standing trees    	Beavers          	3	Incident	625,000
CA	1990	Cattle, calves    	Coyotes          	1,833	Each    	580,569
UT	1991	Sheep, lambs      	Coyotes          	9,488	Each    	547,065
CA	1990	Sheep, lambs      	Coyotes          	6,479	Each    	519,294
TX	1990	Exotic game mammals	Coyotes          	1,311	Each    	518,880
UT	1990	Sheep, lambs      	Coyotes          	8,944	Each    	518,146
TX	1990	Cabbage           	Blackbirds       	6	Incident	517,900
LA	1991	Sugarcane         	Nutrias          	1	Incident	504,000
Of ADC's 12,060 damage records for 1990, 1991, and 1992, 37 report damage exceeding a half million dollars. Some of these represent individual incidents, but others are accumulations of a given type of incident in a particular state. Source: ADC 1992 report, table 4a.

The numbers in ADC's records are not all verified by ADC personnel, but ADC does attempt to find out if they are reasonable. Yet these numbers are something less than the total actual damage reported to the ADC. The ADC's new management information system (MIS) records total damage reports. As of 1992, this system was on line only for livestock in five states. The reports from those states tended to be much greater than reported by the older system. The difference is that the ADC makes no attempt to determine whether the larger numbers reported by the MIS project are reasonable.

Obviously, many animal damage problems are never reported to ADC. As will be shown later, only about 10 to 25 percent of cattle and sheep predation is recorded in ADC's reports, and the recorded percentages for other activities--such as the amount of clothing damaged by mice--may be far smaller.

Clearly, an important selection process is going on here. Before an animal damage incident can be recorded in ADC's files, the person suffering the damage has to know about ADC and that it takes such reports. Even more, people are likely to file reports only if they expect ADC to help them with the problem.

For example, sunflowers are grown in many states with particularly large crops being grown in Minnesota, South Dakota, and Kansas. Yet ADC's records show animal damage only to sunflower crops in North Dakota. This is not because there is no damage in other states, but because ADC's blackbird control program is located in North Dakota.

Eventually, animal damage reports become self-fulfilling prophecies. Without a government agency like ADC, farmers will expect some animal damage and will take whatever steps they can afford to minimize that damage. When ADC enters the picture, farmers will reduce their own efforts because they expect ADC to solve their problem. This reduction in farmer efforts increases the amount of damage. Increased damage reports give ADC an opportunity to ask Congress for more funds. Increased funds allow them to serve more farmers and protect more crops, and the process cycles through again.

For example, research shows that sheep growers can reduce the risk of coyote predation by placing their sheep and lambs in lighted pens at night.[5] This is the practice of many farmers in states with minimal ADC livestock programs. But where ADC has significant programs, farmers will let their sheep range free at night and rely on the government to kill coyotes for them. Despite ADC's efforts, the effect is greater losses to predation--which to some becomes an argument for more ADC funding.

Some of the reports recorded by ADC seem rather fantastic. Many farmers question whether a coyote can kill a healthy calf, much less adult cattle. Yet, between 1990 and 1992, ADC records report coyotes killing nearly 24,000 calves and 1,000 adult cattle, not to mention 36,500 sheep, over 80 horses, and 500 full-grown pigs.

We can believe that Texas alligators are capable of killing ducks and possibly even the calf reported in 1990. We might be able to believe reports that black bear killed 90 adult cattle and several horses. But some of the following reports are hard to accept:

Some of the more unusual reports come from only one state: A number of reports indicate damages something less than total: Texas has the nation's most valuable herds of livestock, so naturally it has the nation's largest animal damage control program. In 1991, it also had some of the most voracious wildlife in the nation. Sometimes these apparent super-predators wandered into neighboring New Mexico. All of the following reports are from 1991 unless otherwise noted: Unbelievable as they are, all these reports might just possibly be true. But if ADC maintains they are true, they raise a number of disturbing questions, such as: The above examples are drawn exclusively from the ADC's livestock reports. Other examples, just as interesting in their own way, can be found in ADC's many reports of gophers, moles, and raccoons disturbing people's lawns and gardens or of magpies, skunks, and feral dogs eating (or, in the case of skunks, perhaps spraying) people's pets.

In general, the only conclusion that can be drawn from this is that ADC's reports are not reliable in any sense. Some of the reported damage probably was not really caused by wildlife. Fluctuations from state to state and year to year are probably more related to the aggressiveness of local ADC employees in collecting reports than of actual damage.

Table Seven
Value of Reported Livestock Predation

A. All Livestock
                        	    1990	   1991	   1992
1. Damage Caused by Mammals
Coyotes                 	 $9,586,696	 $9,951,335	 $3,155,779
Wild cats               	  1,839,206	  1,203,049	    341,477
Feral dogs              	    711,310	    499,784	    280,779
Bears                   	    265,338	    206,226	    129,343
Raccoons                	    241,707	    126,167	     34,202
Skunks                  	    162,019	     23,550	    146,648
Wolves                  	     69,644	     49,721	     41,129
Other ferals or exotics 	     64,499	     75,012	      3,767
Other mammals           	      5,995	     59,108	      6,319
2. Damage Caused by Birds
Blackbirds              	    818,700	    207,655	    366,100
Golden eagles           	    410,388	    299,743	     13,463
Vultures                	     35,186	     74,956	     21,189
Ravens                  	     54,119	     51,588	     18,217
Bald eagles             	     19,994	     42,119	        376
Hawks, Falcons, Osprey  	     19,951	      9,227	     27,029
Starlings               	          0	      2,500	     12,740
Crows                   	      4,565	      1,845	        242
Waterfowl               	          0	          0	      2,771
Song birds              	          0	        120	        131
3. Damage Caused by Other Animals
Alligators              	        450	          0	         12
Snakes                  	     17,390	      7,570	         55
Lizards                 	          0	          6	          0
Turtles                 	          0	          0	        168
TOTAL                   	$14,327,156	$12,891,280	 $4,601,936
B. Cattle
                        	    1990	   1991	   1992
1. Damage Caused by Mammals
Coyotes                 	 $3,428,717	 $4,891,245	 $1,033,036
Wild cats               	    381,486	    192,179	     45,642
Feral dogs              	    216,161	    168,848	    137,884
Bears                   	     96,777	     54,164	     22,978
Wolves                  	     39,148	     32,544	     35,600
Other ferals or exotics 	      1,350	      5,575	      2,000
Skunks                  	        784	          0	        600
Other mammals           	        400	          0	        230
2. Damage Caused by Birds
Blackbirds              	    818,700	    207,650	    366,100
Vultures                	     27,358	     43,900	     18,465
Ravens                  	     35,812	     22,200	      9,259
Starlings               	          0	      2,500	     12,340
Golden eagles           	      7,095	      1,810	        200
Waterfowl               	          0	          0	      2,400
Bald eagles             	          0	        250	          0
Song birds              	          0	          0	          1
3. Damage Caused by Other Animals
Snakes                  	        700	      4,620	          0
Alligators              	        450	          0	          0
TOTAL                   	 $5,054,938	 $5,627,485	 $1,686,735
C. Sheep
                        	    1990	   1991	   1992
1. Damage Caused by Mammals
Coyotes                 	 $4,657,006	 $3,874,274	 $1,958,163
Wild cats               	    877,011	    704,151	    246,225
Feral dogs              	    366,993	    250,685	     85,267
Bears                   	    165,664	    146,684	     97,697
Raccoons                	     23,496	     22,294	        834
Skunks                  	      6,005	      5,400	        193
Wolves                  	     13,399	      4,793	      2,881
Other ferals or exotics 	     30,651	     21,573	        899
Other mammals           	     1,180	      5,020	        100
2. Damage Caused by Birds
Golden eagles           	    298,028	    192,929	     12,983
Bald eagles             	     14,034	     29,640	     13,148
Ravens                  	     17,587	     24,598	      8,254
Vultures                	      1,693	     19,290	      1,212
Hawks, Falcons, Osprey  	     10,020	      3,565	          0
Crows                   	      3,475	      1,845	        168
Song birds              	          0	        120	          0
3. Damage Caused by Other Animals
Snakes                  	     10,340	      2,950	          0
TOTAL                   	 $6,496,581	 $5,309,810	 $2,428,024
Source: ADC 1990 report, table 4, and 1992 and 1991 reports table 4a.

Protecting Livestock

The primary activity by the ADC program on behalf of western livestock is killing coyotes. The number of coyotes killed or removed in the Western Region grew from around 75,000 per year between 1985 and 1988 to nearly 100,000 per year in 1992. Fewer than 130 coyotes were killed in the Eastern Region in 1992.

By comparison, the Eastern and Western regions together reported killing fewer than 60,000 mammals of all other types in 1992. Among these are about 1,200 bobcats, 600 feral dogs, and 200 bears--all potential threats to livestock. Most of the other species killed were beavers (15,100), foxes (10,600), skunks (7,900), raccoons (7,600), and opossums (2,800). With the possible exception of foxes, these are not serious threats to livestock.

ADC's policy is to treat an animal damage problem only after receive a report from someone that wildlife have harmed their livestock, crops, or property. ADC offers consultative advice to property owners who suffer such damage.

In 1992, out of 40,600 consultations offered by ADC, only 1,342 such consultations related to coyotes and only 1,600 agricultural consultations related to species that seriously threaten cattle or sheep. By comparison, ADC had 3,800 consultations on raccoons, 3,300 on squirrels, 3,100 on skunks, 2,400 on geese, 2,200 on deer, 1,500 on beavers, and 1,400 on blackbirds. A total of 40,600 consultations were made on all species.

Once called into action, ADC workers use a variety of means to kill coyotes and other large predators. The most effective is aerial, either helicopter or airplane. Together these killed a reported 32,700 coyotes in 1992, or more than a third of the total. Next is the M-44, which killed about 25,200, or more than a quarter of the total. Leghold traps killed 13,300, while the rest were killed via snares (10,000), calling (7,400), denning (killing pups in their dens, 3,300), shooting (3,700), or "other" (2,200).

Assuming that half of ADC's livestock protection budget is dedicated to killing coyotes, the average cost per coyote over the past eight years is more than $100. This ranges from under $75 in Nebraska to over $150 in Utah. Adding APHIS and ADC overhead would increase these costs by about 20 percent.

In some cases, the costs can be much higher. In nine states, ADC regularly rents helicopters to hunt coyotes. Based on ADC reports of the cost of helicopter rental per hour and the number of coyotes killed per hour, the rental cost per coyote ranges from $25 to over $2,000, for an average of well over $150. Since other costs are involved, including personnel and overhead, $100 per coyote seems a conservative figure.

Would each of the 100,000 coyotes killed by ADC do more than $100 worth of damage to livestock if left unchecked? An accurate answer depends on detailed biological information that is not available at this time. In many cases, however, the answer is "no."

After ADC receives a complaint that predators are killing a rancher's livestock and verifies that the livestock were killed by predators, ADC attempts to suppress predators in the local area. However, there is no guarantee that the coyotes killed are the ones that killed the livestock or that they would have killed any if left alive. It is likely that many of the coyotes killed would never have preyed on domestic livestock.

State-by-State Comparison

The major problem with reviewing a program like animal damage control is that it is difficult, if not impossible, to determine the actual benefits of the program. As pointed out by political scientist William Haga, bureaucracies tend to count inputs, not outputs, for the good reason that the outputs are difficult to count.[6] If the outputs were easy to count, the business of the bureaucracy could be conducted by the private sector and there would be no need for the bureaucracy.

In the case of ADC's livestock protection efforts, the output that is being sought is livestock that are not eaten by predators that would have been eaten were it not for ADC. This is obviously difficult to measure. So instead, ADC concentrates on inputs--numbers of coyotes killed, numbers of lambs that are killed by coyotes, etc.

The one opportunity to compare actual outputs is to compare differences in ADC programs among the different states. Although ADC is run by the federal government, individual states have taken different approaches to predator control. A comparison of these different approaches may reveal that some states are more successful and/or spend less than others.

The following tables contain state-by-state breakdowns of ADC budgets and activities. Tables eight through twelve are based on ADC data for 1992. These data are collected in a dozen or so tables used internally by ADC. For example, table 1 shows how much money is spent in each state, on what resource, and where the money comes from, while table 4 shows the wildlife damages reported to ADC each year.

Tables thirteen through sixteen are based on data collected by the National Agricultural Statistics Service--some of it under contract to ADC--for 1990 and 1991. ADC combines New Hampshire and Vermont in some its records, so for comparability these states are combined in all tables.

Overall ADC Budgets

Table eight shows ADC's 1992 budget in each state, including both federal ADC funds and cooperator funds. The table shows that Texas has the largest ADC program, with a budget greater than the next two states combined (California and New Mexico). Texas also receives the largest share of federal funds even though the federal government provides just a third of the Texas ADC budget.

Fifteen states, all but one of them from the Western Region, have budgets of more than a million dollars. Altogether, the Western Region accounts for well over 80 percent of the 1992 state budgets.

The federal government provides 100 percent of the funding in seven states and the District of Columbia. Of these states, significant ADC programs are maintained only in Maine, Florida, Pennsylvania, and Iowa. The federal government provides a third or less of the funds in Texas, South Dakota, New Jersey, and Hawaii. But it provides over half the funds in more than 40 states and between 75 and 99 percent of the funds in 17 states.

Table Eight
Overall 1992 ADC Budgets

	Federal		Coop.		Total	Percent 
State	Funds	Rank	Funds	Rank	Budget	Federal
TX	2248462	1	4551609	1	6800071	33
CA	1912539	2	2122723	2	4035262	47
NM	1097422	3	902,019	3	1999441	55
UT	958,209	4	747,251	5	1705460	56
WY	942,559	6	718,326	6	1660885	57
OR	942,030	7	690,699	7	1632729	58
MT	944,301	5	575,804	11	1520105	62
OK	756,594	10	660,032	8	1416626	53
ID	899,413	8	358,101	14	1257514	72
NV	692,564	12	539,602	12	1232166	56
WI	510,000	14	656,738	9	1166738	44
SD	355,786	17	790,500	4	1146286	31
ND	812,109	9	317,442	15	1129551	72
WA	521,929	13	590,217	10	1112146	47
CO	739,421	11	289,470	16	1028891	72
AZ	449,426	16	272,231	17	721,657	62
MS	488,000	15	150,900	21	638,900	76
HI	86,570	34	504,956	13	591,526	15
NE	307,180	18	164,478	20	471,658	65
TN	221,330	22	214,366	18	435,696	51
LA	299,955	19	43,316	27	343,271	87
NJ	83,256	36	209,265	19	292,521	28
NY	136,814	25	136,998	22	273,812	50
MN	253,536	20	9,512	40	263,048	96
NH/VT	205,500	23	55,330	24	260,830	79
AR	240,000	21	19,092	34	259,092	93
KY	74,770	40	131,562	23	206,332	36
OH	156,000	24	40,000	28	196,000	80
VA	112,000	27	43,858	26	155,858	72
ME	125,000	26	200	43	125,200	100
NC	100,000	30	23,625	32	123,625	81
MO	100,000	29	22,500	33	122,500	82
GA	93,000	32	28,899	30	121,899	76
IL	74,000	41	38,264	29	112,264	66
MI	99,000	31	12,758	38	111,758	89
MD	86,680	33	25,000	31	111,680	78
AL	100,000	28	4,732	42	104,732	95
WV	85,602	35	15,295	36	100,897	85
IN	83,000	37	16,696	35	99,696	83
AK	50,100	44	46,863	25	96,963	52
SC	82,399	38	7,135	41	89,534	92
FL	80,000	39			80,000	100
PA	66,585	42			66,585	100
MA	50,203	43	14,900	37	65,103	77
CT	30,447	46	12,295	39	42,742	71
IA	35,000	45			35,000	100
KS	3,000	47			3,000	100
RI	1,646	48			1,646	100
DC	792	49			792	100
DE	528	50			528	100
TOTAL	18794657		16775559		5570216	53
States are listed in order of the total ADC budgets. Source: ADC 1992 report, table 1a.

ADC Livestock Protection Budgets

Table nine highlights the 1992 livestock budgets, showing where the cooperator funds come from in each state. Texas and California are once again the top two states, but Wyoming has supplanted New Mexico in the number three slot. New Mexico puts a larger share of its funds into forest/range and crops.

Nearly 98 percent of ADC's livestock budget is concentrated in the 16 contiguous western states (excluding Kansas). Within those states, the federal government funds only about a third of the program in Texas and South Dakota, but over half in most other states and nearly two-thirds or more in Montana, Idaho, Colorado, Arizona, Washington, and Nebraska. Outside the West, the largest ADC livestock program is in Minnesota, which is entirely funded by the federal government.

The different states use various methods to fund their ADC programs. The California program is funded mostly by the counties. Texas is shared by the state and local organizations. Utah and North Dakota rely mostly on state funds. In many cases, however, county and state funds may merely be a pass-through of assessments charged to livestock ranchers.

Five states receive no funding at all, and funds in at least 23 other states are inadequate to support even a single full-time employee. Most of these states rely almost entirely on federal funds.

Table Nine
ADC Livestock Protection Budgets

	Indi-	Organi-			Fur 	Revolv.	Federal 			Percent
State	vidual	zation	County	State	sales	fund	agency	ADC	TOTAL	ADC
TX		1360659		1385604				1461501	4207764	35%
CA			1169281	370,748			163,241	1644784	3348054	49%
WY	756	47,206	582,660	56,000	13,024		10,000	895,431	1605077	56%
NM		51,793	401,049	285,240	8,637			804,410	1551129	52%
UT				627,230	2,547	47,174		862,582	1539533	56%
MT			183,571	314,189	8,204			928,216	1434180	65%
NV		88,526		405,912				631,623	1126061	56%
ID		322,757					1,235	687,846	1011838	68%
CO	2,150	188,286	67,434	31,600				699,340	988,810	71%
SD			237,083	235,711	6,172	169,244		249,168	897,378	28%
OR	2,075		263,000	149,000				457,000	871,075	52%
AZ		100,989	37,342	75,000			6,000	395,791	615,122	64%
OK	6,425		37,320	210,813		12,950		303,837	571,345	53%
ND				223,528				219,234	442,762	50%
WA		2,140	1,752	137,305				235,455	376,652	63%
NE			70,198		7,743		10,000	154,591	242,532	64%
MN								179,256	179,256	100%
VA				30,000				40,660	70,660	58%
OH				40,000				4,700	44,700	11%
LA								37,395	37,395	100%
MS		1,953		1,050			560	18,160	21,723	84%
NH/VT	300			5,600				9,864	15,764	63%
WI				8,250				7,033	15,283	46%
WV								14,140	14,140	100%
AL								12,700	12,700	100%
IA								12,348	12,348	100%
ME								11,750	11,750	100%
TN								8,809	8,809	100%
GA	43							5,581	5,624	99%
IL								5,448	5,448	100%
MO								5,269	5,269	100%
MI								4,949	4,949	100%
FL								4,500	4,500	100%
SC								4,120	4,120	100%
IN								3,508	3,508	100%
PA								3,296	3,296	100%
KY								2,812	2,812	100%
NC								1,540	1,540	100%
MD				187				647	834	78%
HI	300							500	800	63%
CT								687	687	100%
MA								600	600	100%
AK								513	513	100%
RI								82	82	100%
TOTAL	12,049	2164309	3050690	4592967	46,327	229,368	191,036	11031676	21318422	52%
States are listed in order of total ADC livestock budgets. ADC spends no funds on livestock programs in Arkansas, Delaware, Kansas, New Jersey, or New York. Source: ADC 1992 report, table 1a.

Value of Reported Losses

Table ten shows the total value of animal damage reported, along with the number of events (incidents, acres, or animals damaged or destroyed), in 1992. The table also shows the number of animals reported killed by coyotes and the value of those animals.

With the largest ADC program, it is no surprise that Texas collects the largest number of damage reports and records the greatest damage value. But states with the third and fourth largest amounts of damage--Arkansas and Massachusetts--have only the 23rd and 44th largest ADC programs. Most of the differences between budgetary and damage rankings can be explained either by a few costly incidents or by Congressional focus on special ADC activities.

Ordinarily, Massachusetts would be ranked much lower, but a single incident between an airplane and birds accounted for 96 percent of the damage it reported in 1992. Nearly 90 percent of the damage reported in Hawaii was also due to a few aircraft incidents.

Arkansas' high ranking is probably due to Congressional interest. Starting in 1988, Congress earmarked nearly a quarter of a million dollars per year to "restore" Arkansas' ADC program. The high reported damages probably reflect this new funding.

Other states with high reported damages also reflect Congressional earmarking. The North Dakota blackbird control program explains that state's number five ranking. Blackbirds caused 82 percent of the damage reported in that state. Congress has funded $100,000 per year each to Mississippi and Wisconsin to control beavers, and beavers were responsible for 86 percent of the damage reported in Mississippi and 40 percent of the damage reported in Wisconsin.

Table ten also shows the value of damage reportedly caused by coyotes. Not surprisingly, the 16 western states with ADC programs form the top 16 in ranking, reporting 96 percent of the total damage due to coyotes.

The next three are Virginia, Ohio, and Minnesota, reporting over half the coyote damage of all the eastern states. These three also happen to be the top ranked eastern states in terms of ADC livestock budgets, receiving 60 percent of eastern livestock funds. As will be shown in table sixteen, among eastern states Virginia ranks only third in actual livestock losses to predators, while Minnesota ranks eighth and Ohio sixteenth. It seems likely that the high reported losses in these three states primarily reflect the states' high ADC budgets.

Table Ten
Value of Reported Losses

	Events	Value of	losses	Coyote	Coyote
State	reportd	damage	reportd	damage	rank
TX	26,213	3686339	3,783	238,729	4
OR	40,422	3327579	3,157	230,880	5
AR	476	2185930	12	1,150	28
MA	15	2078740			
ND	3,831	1895694	1,944	215,456	7
HI	303	1712955			
CA	13,303	1674396	4,183	247,436	3
OK	7,149	1402438	3,228	189,513	10
WA	5,668	1395505	943	129,336	12
WI	5,845	1253958	314	6,885	22
MS	1,359	1104842			
NM	25,224	735,173	924	104,742	14
AZ	1,618	683,650	262	55,097	16
NC	259	682,985			
LA	1,707	675,625	123	3,104	26
NE	17,523	493,902	822	59,280	15
SD	3,386	453,970	1,983	160,150	11
IN	301	436,605	5	85	31
UT	5,909	429,984	3,534	221,346	6
WY	7,759	421,045	7,194	393,180	1
MD	7,886	403,646			
VA	2,639	344,044	496	35,028	17
CO	4,676	343,122	3,198	192,826	9
MN	603	341,671	203	17,559	19
MT	4,859	332,085	3,776	291,547	2
KY	2,941	310,135			
PA	228	277,215	7	525	29
TN	556	275,459			
ID	4,777	264,414	3,009	205,939	8
AL	2,033	258,330	40	15,650	20
NV	3,178	238,569	1,810	122,120	13
OH	1,061	234,229	363	19,715	18
NH/VT	2,384	142,170	157	5,576	23
MO	808	100,844	8	200	30
CT	2	78,000			
WV	3,983	60,428			
MI	268	43,231	64	3,631	25
NJ	54	42,000			
IL	3,382	27,500	40	4,100	24
GA	37	27,025	7	2,190	27
SC	210	18,323			
IA	242	15,350	212	10,400	21
ME	10	10,000			
DE	19	9,350			
AK	63	8,960			
DC	15	6,000			
RI	1	1,000			
TOTAL	215,184	30944414	45,801	3183375	
States are listed in order of total damage reported. Blanks should be interpreted as zeros; thus, no damage was reported in Florida, Kansas, or New York. Source: ADC 1992 report, table 4a.

Coyote Take and Harvest

As shown in table eleven, ADC killed nearly 98,000 coyotes in 1992. All but 129 of these were in the Western Region. All but 20 of those killed in the Eastern Region were in Minnesota, Virginia, and Ohio.

Aerial shooting, the most popular way of killing coyotes, was responsible for about a third of the "take," as ADC calls it. Chemical devices such as M-44s did a quarter, and traps and snares another quarter. The rest was done by such means as calling, denning, or just plain shooting on sight from the ground.

These proportions varied only somewhat by state. California seems to mostly avoid aerial shooting, but Wyoming, Nevada, Idaho, Utah, and Colorado rely on it for well over half their take. M-44's are dominant in Nebraska, New Mexico, and, to a lesser extent, the Dakotas. The eastern states rely almost exclusively on traps and snares.

Table eleven also shows the harvest by private fur trappers. Since 1992 numbers were not available for every state, the most recent year recorded was used. If the resulting number--284,000--is reliable, it is substantially greater than the 153,000 reported for 1990 in the Western Region PEP report. The 119,000 reported for the Western Region was more than double the PEP report's 1990 level, even though no numbers were reported at all for New Mexico.

Table Eleven
Coyote Take and Harvest

			Leghold		Call-		Den-		Other	Other	Private
State	Total	Aerial	traps	Snares	ing	Shot	ning	M-44	Chem.	Nonch.	Hvst.
TX	19,255	3,814	1,682	4,686	914	312	187	7,579	17	64	98
NM	8,252	1,175	1,018	665	581	158	4	4,638		13	na
SD	7,582	2,497	413	745	491	88		2,186	1,149	13	7,959
OR	7,442	2,716	2,223	931	357	273	151	739		52	3,849
WY	7,320	4,499	595	169	927	390	212	527		1	6,032
MT	6,816	3,665	476	564	393	236	408	1,074			7,532
NV	6,124	3,706	1,073	77	586	340	217		27	98	3,718
CA	5,926	76	1,720	505	529	1,049	423	1,277		347	1,536
ID	5,333	3,428	721	83	639	65	30	356		11	2,583
OK	5,284	1,623	612	387	781	184	71	1,623		3	1,617
UT	4,933	2,062	320	152	586	81	951	719	4	58	3,271
CO	3,261	1,817	78	173	330	141	341	272		109	28,707
WA	3,179	461	766	242	180	188	257	1,004		81	1,875
ND	3,150	634	554	562	39	36	88	1,214		23	8,562
NE	2,483	320	181	26	59	63		1,724	110		16,316
AZ	1,503	274	841	1	33	47		307			25,500
MN	60		58	2							19,000
VA	25		3	20	2						
OH	24		16	8							102
MS	14		14								43,191
IN	6										1,029
KY											53,553
AL											21,100
MI											5,500
IA											4,500
MO											3,919
IL											3,010
PA											2,136
KS											1,800
GA											1,656
NY											1,403
ME											1,222
NH/VT											813
AR											129
TN											98
CT											77
LA											66
MA											58
SC											30
RI											2
MD											1
TOTAL	97,972	32,767	13,364	9,998	7,427	3,651	3,340	25,239	1,307	873	283,550
States are listed in order of the number of coyotes taken by ADC. No coyotes were recorded as killed by ADC or private trappers in Alaska, Delaware, Florida, Hawaii, North Carolina, New Jersey, Wisconsin, or West Virginia. Source: ADC 1992 report, table 2.

Reported Cattle and Sheep Losses to Coyotes

Table twelve shows the number and value of adult cattle, calves, adult sheep, and lambs reported lost to coyotes in 1992. Only 29 states reported any such losses, with 96 percent of the losses reported by the Western Region.

Table Twelve
Reported Cattle & Sheep Losses to Coyotes

	Adult Cattle	Calves		Adult Sheep	Lambs		Total	
State	No.	Value	No.	Value	No.	Value	No.	Value	Value
WY	5	3,500	42	16,800	1,734	104,040	5,362	268,100	392,440
MT	1	687	222	92,170	399	27,778	3,042	166,913	287,548
CA	221	3,507	220	89,196	356	18,561	2,110	121,469	232,733
OR	5	2,950	328	85,800	372	19,173	2,082	118,237	226,160
UT			27	6,885	1,106	76,903	2,348	136,508	220,296
ND	13	7,375	258	106,110	187	13,730	1,031	76,030	203,245
ID	3	2,316	208	17,056	515	35,432	2,138	147,094	201,898
CO			9	3,925	288	21,350	2,532	156,917	182,192
TX	27	14,430	285	96,029	364	18,202	1,136	47,132	175,793
SD			253	73,550			1,730	86,600	160,150
NV	25	14,350	49	9,034	356	34,293	1,312	75,487	133,164
OK	18	11,080	1,388	107,065	66	5,115	175	9,765	133,025
WA	4	3,090	219	88,835	113	10,825	275	20,660	123,410
NM	19	9,127	170	55,021	155	11,314	459	22,940	98,402
NE	5	4,750	116	35,015	88	6,375	184	9,495	55,635
AZ	2	1,600	70	39,740	33	4,317	80	5,965	51,622
VA	1	1,000	8	3,203	20	1,280	467	29,545	35,028
OH			31	4,000	16	1,575	244	12,215	17,790
MN	2	1,025	27	10,578	4	389	79	4,325	16,317
AL			24	14,250					14,250
IA			6	2,450	4		200	7,650	10,100
WI	2	320	9	3,830	14	800	285	1,525	6,475
NH/VT	2	1,000	5	575	16	1,330	38	3,335	6,240
IL	1				39	4,100			4,100
GA			6	2,130			1	60	2,190
LA			41	942	5	400	5	190	1,532
AR	10	1,000							1,000
PA							7	525	525
IN					1	65			65
Total	366	83,107	4,021	964,189	6,251	417,347	27,322	1528682	2993325
States are listed in order of the total value of sheep and cattle reported lost to coyotes. No losses were reported in Alaska, Connecticut, Delaware, Florida, Hawaii, Kansas, Kentucky, Massachusetts, Maryland, Maine, Michigan, Mississippi, Missouri, North Carolina, New Jersey, New York, Rhode Island, South Carolina, Tennessee, or West Virginia. Source: ADC 1992 report, table 4a.

Cattle and Sheep Losses

More complete information about cattle and sheep losses was gathered by the National Agricultural Statistics Service (NASS) under contract to the ADC. Cattle and calf loss data were gathered for 1991 and are shown in table thirteen.[7] Table fourteen contains the sheep and lamb loss data gathered for 1990.[8] The tables show losses to both predators in general and coyotes in particular.

NASS collected data through sampling surveys of farmers and ranchers in every state except Alaska conducted by phone, mail, and in person. Surveys collected information from 65,000 sheep growers and 77,000 cattle growers. NASS estimates that the sheep data have a 95 percent chance of being accurate within plus or minus 8 percent, but did not estimate accuracy for the cattle survey. Of course, the surveys' reliability depends on the accuracy of the information supplied by survey respondents, which NASS did not estimate.

Tables thirteen and fourteen also show the size of the cattle and sheep herds and calf and lamb crops in the years of the surveys. These data are published by NASS in its annual report of agricultural statistics.[9] Table fifteen compares NASS' estimates of predator losses with ADC's reports for the relevant years, 1991 for cattle and 1990 for sheep.

Cattle and Calves

Table thirteen shows that cattle growers lost, on the average, only about 0.02 percent of adult cattle and 0.2 percent of calves to predators. The NASS cattle survey also looked at other causes of loss and found that growers lose almost three times as many animals to the weather, five times as many to calving, 25 times as many to digestive or respiratory ailments, and ten times as many to other causes, including poisoning and theft. Of the various causes of cattle loss surveyed by NASS, predators were the least important.

Two-thirds of the calf losses, but only a third of the adult losses, were estimated to be due to coyotes. Feral dogs were responsible for most of the other losses, with mountain lions a distant third.

Losses to predators vary dramatically by state, ranging from just 0.02 percent of Ohio calves and no Ohio adults to 1.1 percent of Arizona calves and 0.2 percent of Arizona adult cattle. Farmers and ranchers in Arizona, Oregon, Nevada, New Mexico, Texas, Oklahoma, Tennessee, Colorado, Utah, and Illinois experienced significantly higher than average calf losses.

Of course, ADC has put enormous efforts into predator control in eight of those ten states. This could merely suggest that ADC's efforts were not enough and should be redoubled. But it could also indicate that ADC's efforts have failed and a completely different method should be applied.

Four of the top ten cattle producing states (Iowa, Missouri, Wisconsin, and Kansas) do not have a significant federal ADC livestock program. Cattle growers from these states all report predator losses that are far less than half the national average.

Table Thirteen
Cattle and Calf Losses

	Total in 1,000s	Losses to Predators		Losses to Coyotes
	Cattle	Calf		Share		Share		Share		Share
State	Herd	Crop	Cattle	herd	Calves	crop	Cattle	herd	Calves	crop
AZ	840	300	1,600	0.19	3,300	1.10	1,300	0.15	1,900	0.63
OR	1,480	650	200	0.01	4,500	0.69			4,000	0.62
NV	540	260			1,600	0.62			1,500	0.58
NM	1,340	480	1,000	0.07	1,800	0.38	200	0.01	1,000	0.21
TX	13,300	5,150	3,000	0.02	23,400	0.45	1,000	0.01	16,200	0.31
OK	5,550	1,900	1,800	0.03	7,000	0.37	1,300	0.02	4,000	0.21
TN	2,250	1,070	400	0.02	4,100	0.38			1,400	0.13
CO	2,750	840	200	0.01	2,900	0.35	100	0.00	2,500	0.30
UT	810	330	100	0.01	1,000	0.30			800	0.24
LA	1,020	500	200	0.02	1,400	0.28	100	0.01	1,200	0.24
IL	2,000	610	200	0.01	1,800	0.30			1,400	0.23
CA	4,600	1,700	1,100	0.02	4,300	0.25	200	0.00	2,600	0.15
KY	2,500	1,210	300	0.01	3,300	0.27	100	0.00	1,800	0.15
HI	214	68			200	0.29				
VA	1,730	805	800	0.05	1,600	0.20			700	0.09
AL	1,800	830	300	0.02	2,100	0.25	100	0.01	1,600	0.19
MS	1,290	680	300	0.02	1,600	0.24			1,300	0.19
GA	1,420	670	400	0.03	1,300	0.19	100	0.01	600	0.09
SD	3,400	1,620	300	0.01	3,700	0.23	100	0.00	3,500	0.22
SC	580	245			600	0.24				
NC	950	450	300	0.03	700	0.16				
AR	1,690	770	300	0.02	1,400	0.18			300	0.04
WY	1,190	640	100	0.01	1,200	0.19			1,000	0.16
ID	1,740	680	100	0.01	1,200	0.18			900	0.13
WA	1,340	540	200	0.01	800	0.15	100	0.01	700	0.13
NH/VT	326	182	100	0.03	200	0.11			200	0.11
ND	1,700	960	200	0.01	1,400	0.15	100	0.01	1,300	0.14
MT	2,330	1,430	300	0.01	1,800	0.13			1,200	0.08
MN	2,760	1,030	100	0.00	1,400	0.14			400	0.04
IA	4,700	1,310	300	0.01	1,600	0.12	200	0.00	1,200	0.09
FL	1,900	980	400	0.02	900	0.09			200	0.02
IN	1,225	460	100	0.01	500	0.11			400	0.09
NE	6,000	1,680	200	0.00	1,800	0.11	100	0.00	1,700	0.10
MO	4,400	2,040	500	0.01	1,800	0.09	200	0.00	1,000	0.05
KS	5,700	1,330	200	0.00	1,100	0.08	100	0.00	800	0.06
WV	515	265			200	0.08				
MD	320	125	100	0.03						
MI	1,200	380	100	0.01	100	0.03				
PA	1,820	770	100	0.01	200	0.03				
NY	1,550	770			200	0.03			200	0.03
WI	4,170	1,780			400	0.02			300	0.02
OH	1,580	600			100	0.02				
AK	8	3								
CT	74	34								
DE	28	11								
MA	70	33								
ME	119	50								
NJ	70	32								
RI	7	4								
Total	98,896	39,256	15,900	0.02	90,500	0.23	5,400	0.01	59,800	0.15
States are listed in order of the total value of cattle and calf losses to predators. Blanks in loss categories mean less than 50 estimated to be lost. Sources: Herd and crop size: NASS, Agricultural Statistics 1992, tables 386 and 389, data for 1991. Losses: NASS, Cattle and Calf Death Losses, pp. 4, 5, and 6.

Sheep and Lambs

Table fourteen shows that sheep growers lost, on the average, 4.5 percent of their lambs and 1.2 percent of adult sheep to predators. NASS' sheep survey did not report other causes of sheep loss. Nearly two-thirds of the estimated predator losses were due to coyotes.

As with cattle, losses vary greatly by state, with lamb losses ranging from 0.8 percent of lambs and 0.4 percent of adults in Michigan to 11.0 percent of lambs and 4.6 percent of adults in Nevada.

High loss rates are calculated for Arkansas, Mississippi, and Alabama, but these numbers are suspect. NASS did not report separate sheep and lamb numbers for these three states in 1990, instead combining them with Florida, Delaware, Georgia, Hawaii, Rhode Island, and South Carolina. The numbers in the table are an average for all nine states, but this probably underestimates the numbers for Arkansas, Alabama, and Mississippi, and may overestimate them for the other states.

Discounting these three states, the states with the top ten losses as a proportion of their herds are all western states except Virginia. As previously noted, Virginia has one of the largest ADC livestock protection programs in the East.

Table Fourteen
Sheep and Lamb Losses

	Total in 1,000s	Losses to Predators		Losses to Coyotes
	Sheep	Lamb		Share 		Share 		Share 		Share 
State	Herd	Crop	Sheep	herd	Lamb	crop	Sheep	herd	Lamb	crop
AR	7	5	200	2.68	800	14.68	100	1.34	400	7.34
NV	97	84	4,500	4.64	9,200	10.95	3,200	3.30	6,300	7.50
MS	7	5	300	4.03	400	7.34	100	1.34	300	5.50
AL	7	5	300	4.03	400	7.34	100	1.34	200	3.67
NM	473	290	10,000	2.11	27,000	9.31	4,300	0.91	10,600	3.66
CO	455	400	9,000	1.98	30,500	7.63	5,900	1.30	26,300	6.58
OK	105	90	3,000	2.86	4,900	5.44	2,800	2.67	4,400	4.89
AZ	220	130	4,000	1.82	7,500	5.77	2,600	1.18	5,100	3.92
OR	345	310	5,100	1.48	18,800	6.06	3,200	0.93	9,900	3.19
UT	485	430	9,300	1.92	22,100	5.14	6,500	1.34	15,000	3.49
TX	1,890	1,150	2,700	0.14	80,000	6.96	1,600	0.08	40,000	3.48
VA	122	130	2,500	2.05	5,500	4.23	200	0.16	3,900	3.00
SD	535	515	8,700	1.63	22,700	4.41	8,200	1.53	20,700	4.02
MT	640	500	7,600	1.19	23,000	4.60	6,100	0.95	19,100	3.82
LA	17	11	400	2.35	300	2.73	200	1.18	200	1.82
IN	82	90	2,000	2.44	2,300	2.56	100	0.12	200	0.22
WY	705	550	5,700	0.81	26,600	4.84	4,300	0.61	21,900	3.98
KY	38	31	500	1.32	1,200	3.87	100	0.26	800	2.58
FL	7	5			300	5.50			200	3.67
NE	135	125	1,700	1.26	4,600	3.68	1,500	1.11	4,200	3.36
CA	775	550	9,900	1.28	17,700	3.22	5,300	0.68	12,800	2.33
ND	152	156	1,700	1.12	5,300	3.40	1,100	0.72	4,500	2.88
ID	270	270	3,600	1.33	7,600	2.81	2,600	0.96	6,200	2.30
IA	400	385	9,400	2.35	5,100	1.32	5,800	1.45	2,900	0.75
TN	12	10			400	4.12			100	1.03
IL	138	160	1,900	1.38	2,800	1.75	700	0.51	1,200	0.75
MO	120	110	1,000	0.83	2,400	2.18	500	0.42	1,500	1.36
KS	185	145	2,000	1.08	1,800	1.24	1,300	0.70	1,300	0.90
OH	205	200	1,500	0.73	3,100	1.55	200	0.10	1,700	0.85
NY	92	67	1,000	1.09	700	1.04	200	0.22	200	0.30
WA	83	75	400	0.48	1,400	1.87	200	0.24	1,100	1.47
ME	20	16			400	2.50			300	1.88
MN	210	225	1,600	0.76	3,200	1.42	300	0.14	1,700	0.76
WV	80	75			1,800	2.40			500	0.67
WI	90	100	500	0.56	1,300	1.30	300	0.33	900	0.90
MI	92	95	400	0.43	800	0.84	100	0.11	200	0.21
NH/VT	42	37			500	1.35			400	1.08
AK	3	1								
CT	10	9								
DE	7	5								
GA	7	5								
HI	7	5								
MA	17	13								
MD	32	23								
NC	15	11								
NJ	14	10								
PA	134	98								
RI	7	5								
SC	7	5								
Total	9,601	7,725	112,400	1.17	344,400	4.46	69,600	0.72	226,800	2.94
States are listed in order of the total value of sheep and lamb losses to predators. Blanks in loss categories mean less than 50 estimated to be lost. Sources: Herd and crop size: NASS, Agricultural Statistics 1992, tables 419 and 423, data for 1990. Losses: NASS, Sheep and Goat Predator Losses, pp. 4, 8, and 9.

NASS Estimates vs. ADC Reports

The ratios of NASS loss estimates to ADC's reported estimates range less than one (ADC reported more losses than NASS found) to 4,100 (NASS found far more losses than ADC reported). The greatest apparent underreporting of losses was in eastern states where ADC has a minimal predator control program.

On the average, ADC's reports of adult cattle losses were about 10 percent of NASS' estimates. ADC's calf loss reports ranged from 15 percent (for predators as a whole) to 19 percent (for coyotes) of NASS'. When just western states are counted, the figures remained the same for adults while for calves ADC's numbers accounted for 20 percent (predators) to 25 percent (coyotes) of losses. ADC's sheep and lamb numbers accounted for 20 percent of NASS' estimated losses to predators and 24 percent of losses to coyotes.

Unfortunately, NASS' numbers are for a single year only--1990 for sheep and 1991 for cattle. Because of problems with the way ADC's reports are collected, these percentages may not hold up for other years.

Table Fifteen
NASS Estimates vs. ADC Reports

	Losses to Predators		Losses to Coyotes
State	Cattle	Calves	Sheep	Lambs	Cattle	Calves	Sheep	Lambs
AL			3					
AR	30	70						
AZ	4	25	10	7	650	29	8	6
CA	7	1	3	2	2	1	2	2
CO	50	47	20	11	100	47	24	12
GA		87				40		
ID	50	3	6	2	0	2	8	2
IN	50	125	67				3	
KS	100	100	26		50	73	17	
KY		1,650						
LA		467				400		
MD	100	0						
MN	10	15	14	32		12		170
MO				2,400				1,500
MT	30	9	30	11	0	6	31	9
NC		233				0		
ND	15	6	9	6	8	6	7	6
NE	50	16	21	14	25	15	19	14
NH/VT	25	200	0		0	200	0	
NM	8	1	5	3	3	0	3	3
NV		14	7	8		16	7	7
OH			3				0	
OK	29	5	16	11	25	3	19	10
OR	11	19	5	10	0	19	5	6
PA			0				0	
SC		50						
SD		25	19	19		24	18	18
TN		4,100				1,400		
TX	10	7	0	3	4	5	0	3
UT	100	3	2	2		2	2	2
VA	1	67	6		0	140	1	
WA	22	4	1	4	11	4	1	3
WI	0	133		29		300		20
WV			0	14			0	4
WY	50	22	8	7	0	19	7	6
Average	9	7	5	5	10	5	4	4
ADC %	11%	15%	20%	21%	10%	19%	24%	24%
States are listed in alphabetical order. States with no ADC reports of predator losses are not shown. Numbers greater than one indicate the number of losses estimated by NASS for each animal reported lost by ADC. Thus, a "100" means that NASS found 100 times as many animals lost as reported by ADC. A "0" means that NASS found fewer than half as many losses as ADC reported. A blank means that either ADC or both reported no losses. Source: ADC 1991 report, table 4a, for cattle and calves and 1990 report, table 4, for sheep and lambs compared with NASS data in tables thirteen and fourteen.

Value of Herds and Losses

Table sixteen combines NASS data from tables thirteen and fourteen with the average values of cattle and sheep reported by ADC in 1992--$500 per adult cattle, $268 per calf, $72 per adult sheep, and $56 per lamb--to calculate the total value of herds and losses by state.

Texas has both the most valuable herds and the most losses. After Texas, however, there is little correlation between herd size and losses. Nebraska, with the second most valuable herds, ranks only 18th in losses, while Kansas, number four in herd value, ranks just 24th in losses.

On the average, farmers lose about $1 worth of livestock to predators for every $1,000 of value in their herds. But farmers and ranchers in Texas, California, Colorado, New Mexico, Oregon, South Dakota, Montana, Arizona, Wyoming, and Utah lose far more. Meanwhile, farmers in Kansas--with the fourth largest herds--lose only 20cents per thousand dollars of value.

In general, the highest losses are suffered by western states with the largest ADC programs. This could reflect different conditions in those states, requiring an aggressive ADC program to support local livestock industries. But if true, then ADC is effectively supporting a submarginal industry. Ending the ADC livestock program in the West would benefit farmers who can grow livestock without serious predator problems.

An alternative view is that the ADC program has failed, and possibly has even increased predator problems. Comparing figures for Kansas, which does not participate in the federal ADC livestock program, with those for Nebraska or Oklahoma tends to support this view.

In the East, losses do not seem to correlate with the size of the state ADC programs. The largest ADC livestock programs in the East are in Minnesota, Virginia, and Ohio. Virginia ranks third among eastern states in total losses and first in losses as a proportion of herd value. But Minnesota--with the largest eastern ADC program--ranks eighth in total losses and just sixteenth in losses as a proportion of herd value. Ohio is also low in the rankings.

Clearly, ADC discriminates against livestock producers in most eastern states. Its support of submarginal operations in the West reduces livestock prices. Its selective support of eastern states gives a few eastern producers an unfair advantage over the others.

Table Sixteen
Value of Herds and Losses

	Herd	Losses	Loss	------ Value of Losses ------	$ Loss
State	value	value	rank	Cattle	Calves	Sheep	Lambs	/$m
TX	8243980	12,425	1	1,503	6,248	194	4,480	1.51
NE	3472960	961	18	100	481	122	258	1.20
OK	3302350	3,261	3	902	1,869	216	274	0.99
KS	3233580	639	24	100	294	144	101	1.95
CA	2846800	3,403	2	551	1,148	713	991	3.78
MO	2765920	938	19	251	481	72	134	1.38
IA	2756140	1,540	12	150	427	677	286	2.84
WI	2578290	216	34		107	36	73	1.52
SD	2204920	3,036	6	150	988	626	1,271	4.56
MN	1686520	718	23	50	374	115	179	2.67
CO	1658030	3,231	4	100	774	648	1,708	4.02
MT	1624650	2,466	8	150	481	547	1,288	0.56
KY	1581252	1,135	16	150	881	36	67	0.93
TN	1415417	1,318	13	200	1,095		22	1.20
FL	1215382	457	29	200	240		17	3.60
IL	1184376	874	21	100	481	137	157	0.72
PA	1133316	104	40	50	53			0.97
ND	1128660	893	20	100	374	122	297	0.28
AL	1125082	755	22	150	561	22	22	0.34
VA	1098534	1,316	14	401	427	180	308	0.79
ID	1088540	1,055	17	50	320	259	426	0.74
AR	1053892	583	26	150	374	14	45	0.67
NY	993,286	165	35		53	72	39	0.43
OH	978,340	308	33		27	108	174	0.20
OR	957,880	2,722	7	100	1,202	367	1,053	0.75
GA	891,822	548	27	200	347			0.55
NM	850,276	3,214	5	501	481	720	1,512	0.61
WY	849,270	2,271	10	50	320	410	1,490	0.80
MS	829,372	622	25	150	427	22	22	0.38
WA	826,236	421	31	100	214	29	78	0.61
IN	747,949	456	30	50	134	144	129	0.51
MI	714,984	150	38	50	27	29	45	0.56
LA	646,860	520	28	100	374	29	17	0.32
NC	598,246	337	32	150	187			0.08
UT	553,250	2,224	11	50	267	670	1,238	0.17
AZ	524,360	2,391	9	802	881	288	420	0.45
SC	357,082	160	36		160			0.45
NV	351,908	1,266	15		427	324	515	0.21
WV	338,995	154	37		53		101	0.61
NH/VT	217,205	132	39	50	53		28	0.09
MD	197,412	50	42	50				0.42
HI	126,280	53	41		53			0.25
ME	75,355	22	43				22	0.30
CT	47,380							
MA	45,852							
NJ	45,214							
DE	17,818							
RI	5,287							
AK	4,978							
Total	61191484	59,138		7,916	23,843	8,093	19,286	0.97
All dollars are in thousands. States are listed in order of the total value of the cattle and sheep herds and calf and lamb crops. The last column shows the number of dollars farmers lost for every thousand dollars of value of their herds. Source: Tables thirteen and fourteen multiplied by average animal values taken from ADC 1992 reports.

Analyzing the ADC Program

The ADC program does more than just kill coyotes and other predators. A recent article in Audubon magazine by Ted Kerasote featured ADC's program of helping sheep ranchers user guard dogs to keep coyotes out of their flocks.[10] By law, at least half of ADC's 1993 and 1994 research budgets are dedicated to non-lethal methods. And ADC is diversifying into other fields, such as aquaculture and transportation.

None of these things change the basic question this report has raised about ADC: Just why is the federal government involved in activities that are mostly of private and almost entirely of local concern? This chapter examines this question in four different ways.

First, are programs like ADC are even allowed under the U.S. Constitution? One hundred years ago, the answer given by any court and most politicians would have been "no." Problems with ADC, which parallel those of many other agencies, suggest that the recent broader view of constitutionality may not be a good thing.

Second, is there any economic justification for ADC programs? To answer this, the report examines ADC's own economic arguments for its existence--and finds them wanting.

Third, if ADC is so bad, then why does it continue? Flaws in our political system keep programs like ADC going even when most people would probably oppose them.

Finally, what would happen if the federal ADC program disappeared? Kansas, which does not participate in most of the federal program, provides a revealing look at life without ADC.

The Constitutionality of Animal Damage Control

The ADC program traces its roots to the Biological Survey of 1896. Yet in reality, anyone 100 years ago who suggested that the federal government should spend millions of dollars each year to kill coyotes for a few sheep ranchers would have been considered a nut.

The mainstream thinking in America at that time was that the federal government was restricted by the Constitution from engaging in any such local activities. As Henry David Thoreau said, "that government is best which governs least." The best anyone could hope for from their government, Thoreau thought, was to be left alone.

For the most part, people at that time did not consider the Constitution to be an unfair or inappropriate restriction on federal powers. While the exact meaning of the Constitution has always been controversial, Americans for the most part were wary of a powerful or spendthrifty federal government. Indeed, the entire federal budget in 1895 was considerably smaller than APHIS's budget today.

Other than rivers and harbors legislation, the few nineteenth-century bills which Congress passed authorizing federal spending on local problems were vetoed by the president. For example, Franklin Pierce vetoed an 1854 bill to provide federal funding for mental hospitals, and Grover Cleveland vetoed an 1884 bill to provide relief to farmers in drought-stricken Texas.

By the 1890s, however, a significant minority of Americans began to advocate a larger federal role in resource management. Originally this movement was restricted to resources already owned by the federal government. Led by Gifford Pinchot and Teddy Roosevelt, these "Progressives" worried that handing public resources over to the private sector would allow large corporations and monopolies to take control of all the wealth in America. While Roosevelt's administration oversaw the establishment of the Forest Service, Bureau of Reclamation, and a few other agencies, the movement waned after Roosevelt left office.

Progressive ideas resurged during the Great Depression, which was seen by many as the failure of capitalism and the free market. Government planning and control, they argued, represented an alternative that would be more humane and better distribute wealth to the masses.

Although preceding the New Deal by two years, the Animal Damage Control Act of 1931 reflects this new view. As later explained by President Franklin Roosevelt, every farmer has a "right" to "raise and sell his products at a return which will give him and his family a decent living."[11] ADC and other federal supports to agriculture aimed to protect that "right."

It is fortunate for the ADC that no one challenged the 1931 law in court, for at least until 1938 the Supreme Court would undoubtedly have declared it unconstitutional. The "strict constructionist" thinking that dominated the Supreme Court at that time was that the federal government had no authority that was not explicitly granted by the Constitution. Since the Constitution said nothing about wildlife, wildlife management was considered exclusively a state or local prerogative.

The original authors of the 1931 law probably hoped to avoid controversy by giving the Department of Agriculture the authority mainly to do research and demonstration projects, adding actual predator control only as an afterthought. But by the end of Roosevelt's term in office, new appointments to the Supreme Court led to a change in thinking that greatly expanded the idea of what the federal government could do.

This new thinking, sometimes called "loose constructionism," did not go so far as to grant the federal government unlimited authority in all areas not expressly denied by the Constitution. But did broadly interpret such parts of the Constitution as the one granting Congress authority over interstate commerce. Recent court rulings have approved of federal regulatory and spending powers over just about any business activity on the ground that the business may at some point cross a state line.

Unfortunately, advocates of government planning and regulation never consider the incentives their programs create. For example, federal agencies intended to regulate private businesses soon find that they can get bigger budgets by supporting the businesses they were supposed to regulate. While government regulation may be legitimate, the people who benefit from such regulation tend to be diffuse, while those who oppose it tend to be concentrated. Thus it is easy for the concentrated ones to turn an agency around to their point of view.

This is similar to the bitter irony that the constitutional doctrine that today allows the federal government to control wildlife was originally established by environmentalists. Challenges to the Endangered Species Act on constitutional grounds were rejected by the Supreme Court when environmentalists argued that the interstate commerce clause legitimized a federal role in wildlife management. This precedent, in turn, legitimizes ADC.

Yet there is an inherent contradiction in this broad constitutional doctrine. If, in effect, there is no limit to federal powers, then why do we need states at all? What do the ninth and tenth amendments to the Constitution--which guarantee that all rights not specifically reserved to the federal government belong to the states or to individuals--mean if the federal government is all-powerful?

This contradiction is most visible in the federal debt that is now spiraling out of control. Other than their votes for presidents and members of Congress, the public has no say in taxes, federal spending, or federal borrowing. By spending constituents' money on local interests, members of Congress can effectively buy their re-election. Even worse, much of the money spent by Congress is borrowed, which is apparently painless because it costs taxpayers little in the short run but it will sap the strength of the country in the long run.

These problems show that the checks and balances that once protected this country have failed. And a major reason for that failure is the Supreme Court's willingness to approve the constitutionality of almost any federal program.

Yet considering the intent of the Constitution--with appropriate separation of powers between federal, state, and private interests--anyone would have a hard time justifying the ADC program.

The ADC program makes sense only in terms of Franklin Roosevelt's doctrine that "every farmer" has a "right" to a fair return is a complete reversal of the Bill of Rights. Roosevelt coupled this with other claimed "rights," many of which Congress has also attempted to enact into law: Yet all of the attempts to legislate these "rights" have failed or backfired. Congress can't create jobs, but it can tax some people and spend the money hiring other people. However, the people who are taxed then have less money to spend and that reduces employment somewhere else.

Minimum wage laws improve the standard of living for people with the lowest paying jobs. But they also reduce the number of people that an employer can hire, leading to unemployment elsewhere.

Federal housing projects have proven disastrous, the social security system is likely to go bust when the baby boomers retire, and federal education programs have imposed so many red-tape requirements on schools that many would be better off not getting federal money.

One problem here is an erroneous assumption that the federal government can do things that the states can't. True, the federal government has a larger tax base than individual states, but it is no larger than the sum of all the states.

But a more serious problem has to do with Roosevelt's conception of "rights." All of the rights in the Bill of Rights are negative rights--guarantees that the government will not interfere in the affairs of individuals and (in the case of the ninth amendment) states. Thus, we have a right to say what we want, worship where we want, assemble with whomever we want without government interference. Nor can the government deprive us of life, liberty, or property without due process of law. Such negative rights are all oriented toward keeping government small and excluding it from our daily lives.

Roosevelt's rights, on the other hand, are all positive rights--guarantees that we will all enjoy a certain standard of living. Government can only make these guarantees by becoming huge and promising to interfere with every aspect of our daily lives--not to mention the lives of every wild animal in the nation.

In fact, government is incapable of following through on these guarantees. It can, for a time, steal from one segment of society--or future generations--and give to another segment or generation. But in the long run these actions will sap the economic vitality of the nation, leaving it vulnerable to recession and economic invasion by foreign businesses.

One possible tactic for Wildlife Damage Review would be to challenge the constitutionality of the ADC program in court. Such a challenge would draw public attention to the inanity of the federal government killing predators in an era when few biologists would support such a program. At the same time, it would be difficult, possibly expensive, and possibly raise the ire of other groups, such as endangered species advocates, who might feel threatened by such a challenge.

The Economic Justification for ADC

Aside from the constitutionality of ADC, economists would ask two questions about a federal ADC program. First, is federal involvement justified by some sort of market failure that prevents efficient control of wildlife? And second, federal involvement justified by an equitability problem that forces some people to pay the costs of things from which other people benefit?

ADC documents and conversations with ADC staff reveal that the agency has developed a number of reasons for justifying its existence. The most important argument is that "wildlife is a publicly owned resource held in trust by state and federal agencies. Government agencies have a mandate to provide for the welfare and perpetuation of wildlife and must . . . respond to requests for resolution of damage and other problems caused by wildlife."[13] This is an equity argument: the public that benefits from wildlife should pay the cost of wildlife damage.

The problem with this argument is that, with a few exceptions, most wildlife are wards of state, not federal, agencies. When ADC was created in 1931, this was true for all wildlife. State ADC programs may be justified on these grounds; a federal program might only be justified for species over which the federal government has assumed control, such as wolves or bald eagles.

A second argument for federal involvement is that "Expanding human populations and the resultant competition with wildlife for limited habitat results in human-wildlife conflicts which are national in scope and, directly or indirectly, affect all components of our society."[14] This is an efficiency argument: Since the problems are national in scope, only a national agency can address them.

This argument is simply unpersuasive. Raccoons eating someone's chicken in California or blackbirds eating sunflower seeds in North Dakota are local problems, not national ones. Defending against foreign invasion is a national problem requiring a federal program. Defending sheep herds and corn fields are not.

The history of ADC indicates that Congress did not create the program because wildlife in general were wards of the federal government or because problems were national in scope. Instead ADC was a direct response to wildlife problems on an near federally owned land. This is an equitability problem: If the federal government owns the land harboring pests, it should pay the costs of controlling the pests.

This might warrant a role for the Forest Service or other public land agencies in controlling predators that wander from land in their jurisdiction. It does not justify a completely separate agency with authority to eradicate or control wildlife on any public or private land.

Another argument was raised by ADC staff members: ADC actually protects wildlife, they argue, because ending ADC would lead farmers and ranchers to begin a far more vicious campaign against predators and other pests. This is questionable: Without the resources of the federal Treasury behind them, ranchers by themselves would probably not have eradicated wolves from most of the nation. But even if it is true, it only justifies action at the state, not federal, level.

ADC's most technical economic analysis to date was prepared for its final programmatic environmental impact statement (EIS), covering its entire program. This EIS will not eliminate the need for environmental assessments on national forests or BLM lands, but will provide an umbrella document for those EAs to refer to.

To date ADC has spent close to $3 million and some eight years preparing this programmatic EIS (table one). It published an initial draft EIS in 1990 and a supplemental draft in 1993. It expects to publish the final in the next few months.

The final EIS that is now in the works will contain five alternatives:

To estimate the effects of each alternative on costs, both to the federal government and to state and private interests, APHIS economists selected nine examples of ADC's activities. Among other things, they compared the costs for protecting sheep from coyotes on a particular piece of public land in Colorado and on a piece of private land in Virginia. Table seventeen presents their tentative results.

Table Seventeen
Alternative Costs of Protecting Sheep from Coyotes

                                  	CO	VA
1.  No action                     	$3,490	$8,285
2.  Current                       	 3,540	 6,995
3.  Non-lethal (if successful)    	12,040	 7,935
3.  Non-lethal (if not successful)	10,030	10,715
4.  Non-lethal before lethal      	 9,490	 9,235
5.  Compensation                  	 7,040	21,800
Comparative costs of alternatives for two sample situations: one in the West (Colorad), one in the East (Virginia). Source: Appendix N of internal draft of ADC's final EIS.

The compensation alternative is interesting not because it is a good one but because it is so bad yet so politically attractive. Given enough pressure from environmentalists, Congress is likely to select such an alternative because it makes everyone happy--farmers and ranchers lose nothing whether their livestock or crops are eaten or not, and wildlife lovers don't have to worry about predators and other wildlife being killed.

The compensation alternative's fatal drawback is its enormous cost, which ADC has probably underestimated. When considering such alternatives, government agencies and legislators rarely, if ever, worry about the possibility that compensation would lead people to change their behavior. In this case, it is likely that a federal offer to compensate losses will lead farmers to greatly increase their claims of reported losses. Losses that, today, farmers consider to be just a cost of doing business will suddenly become losses for which farmers will believe they have a "right" to compensation.

ADC does not assume that a compensation program will lead to such an increase in reported losses. But it does assume that any losses must be verified prior to compensation. In the ADC's coyote examples, the costs of verification greatly exceed the actual compensation payments. Thus, the greatest beneficiary is the bureaucracy.

So the compensation alternative, though politically attractive, should be unpalatable to anyone concerned about the health of the economy. Under ADC's estimates, alternatives 3 and 4, which restrict the use of certain methods, are significantly more expensive than the current direction.

Surprisingly, however, ADC's estimates show that the no action alternative is usually no more expensive than the current direction. In the Virginia sheep farm case, the no action alternative is 18 percent more expensive than the current direction. But in five of the eight other cases studied by the ADC, the no action alternative costs no more--and, in the Colorado sheep case, costs less--than the current direction (table eighteen).

Table Eighteen
Comparison of No Action and Current Direction Costs

                                                	Action	Current
Sheep on Colorado public land                   	$3,490	$3,540
Sheep on Virginia private land                  	 8,285	 6,995
Cattle egrets near Texas residential area       	 1,300	 1,300
Cattle egrets near Arkansas airport             	79,500	36,200
Beaver in Texas pasture                         	 1,850	 1,850
Beaver in Texas forest                          	   500	   500
Disease-carrying blackbirds near Kentucky school	12,100	 6,400
Starlings near Vermont dairy farm               	 2,270	 1,420
Protecting endangered plover from gulls in NY   	77,900	77,900
In these scenarios projected by APHIS economists, the no action alternative usually costs no more than the current direction. Source: Appendix N of internal draft of ADC's final EIS.

The major exception is the case of protecting airplanes in an Arkansas airport from cattle egrets. But the main reason why the no action alternative costs so much more than the current direction is that ADC assumed that, without a federal ADC program, the airport would have to pay a consultant $40,000 to tell them how to solve the problem. The remaining difference in costs results from ADC's assumption that it could "loan" the airport materials that otherwise the airport would have to buy.

Similar reasons--consultant costs and purchasing rather than borrowing materials--explain the difference in costs in the Kentucky example. In the Vermont dairy farm example, ADC assumes that it could eliminate 80 percent of forage losses to starlings while the farmer without ADC's help would only be able to eliminate 20 percent of the forage losses.

These assumptions--that the government is smarter and more efficient than private individuals--run counter to most people's experience. In all probability, the overall no action alternative would cost no more, and may cost less, than the current direction. The no action alternative also has the virtue of shifting most of the costs to the people who benefit, rather than having federal taxpayers bear much of the burden.

The Politics of Animal Damage Control

The late Tip O'Neill, Speaker of the House during much of the 1980s, made famous the statement that "all politics are local." As a program of the federal government paid for by federal taxpayers, ADC is supposed to be national in scope. In fact, it is really proof of O'Neill's statement as it is mainly directed toward local special interests.

This can be seen by two major actions taken by Congress toward ADC in the past decade. First, angered by a proposal by a secretary of the interior (who by then was out of office), Congress transferred ADC from the Fish and Wildlife Service to APHIS. This transfer was followed by a boost in ADC's budget.

Second, since the transfer Congress has begun to earmark a growing share of ADC's budget to specific states and problems. Starting at less than $700,000 in 1987, earmarking to specific states or regions grew to more than $4 million by 1992, or better than 10 percent of ADC's budget. Local earmarking has fallen to some $2 million in 1994, but the agency continues to fund activities in states like Montana and Utah at the earmarked levels.

Anyone familiar with Congress would predict that the biggest agriculture subsidies would go to states whose delegations sit on the agriculture subcommittees of the House or Senate appropriations committees. States with powerful members on the House or Senate agriculture committees would also get significant subsidies.

Table nineteen shows that this prediction is correct. All of the local earmarks but one went to states with members on the appropriations or agriculture committees. The largest earmarks went to states with members on the agriculture subcommittees of the appropriations committees. In most cases, the Senate, rather than the House, seems to be the controlling factor.

North Dakota has received the most money of any state--nearly $4 million to date. So it is no surprise to find that that state's senior senator, Quentin Burdick, chairs the Agriculture Subcommittee of the Senate Appropriations Committee. Moreover, the state's junior senator also happens to be on the same subcommittee--an unusual circumstance in Congress but one that allows them to direct all sorts of agriculture subsidies to their state.

Most other state earmarks can also be explained by the presence of senators or representatives from those states on the agriculture subcommittees. Where no one can be found on the agriculture subcommittee, they often can be found playing important roles on the appropriations committees proper. For example, Oregon Senator Mark Hatfield is the senior Republican on the Senate Appropriations Committee and probably has much to do with the earmarking directed to the Northwest. Washington Representative Tom Foley's status--currently Speaker of the House and previously a top-ranking member of the House Agriculture Committee--may also play a role.

Changes in committee memberships also explain the timing of the earmarks. For example, Louisiana received no money earmarked just for it until 1994, shortly after its Senator, Bennett Johnston, took a seat on the Agriculture Subcommittee of Senate Appropriations.

These correlations do not prove that the individuals named in the table were directly responsible for the earmarks. Such proof would require a careful reading of tens of thousands of pages of hearing records and might not even be possible then because much appropriations committee work takes place behind closed doors. But the strong correlations here help identify who is likely to oppose major reductions in the ADC program.

Members of the agricultural committees tend to be less environmentally inclined than members of the interior committees. Thus, now that ADC is in the Department of Agriculture, environmentalists will have a harder time cutting the program's budget. In fact, this very thought might have contributed to ADCs move out of Interior.

The immediate political problem today is not where ADC is located but the Western Region report on ADC's effectiveness. This report is probably the first step in a concerted effort by ADC and western livestock ranchers to promote a major boost in ADC's funding. Environmentalists may consider themselves lucky if, at the end of this budget season, they have held ADC's budget to 1994 levels.

The best short-term tactic for groups like Wildlife Damage Review would be to identify members of the agriculture subcommittees of the appropriations committees who are not from the West--even better if they are not from one of the states that receives earmarked ADC funds. Wildlife groups in their states or congressional districts should be contacted and urged to pressure their representatives to reduce funding for predator control.

Table Nineteen
Local Earmarks (1987-1994) and Probable Supporters

State or             Total     Probable Supporter(s)     Position of Supporter      
Region        Years  1000s                                                          
Alabama       91-94    $400    Senator Howell Heflin     Ag Committee               
Arkansas      89-94   1,457     Senator Dale Bumpers     Ag Subcommittee of         
                                                         Appropriations Committee   
AZ, CA, NV    87-90     400    Sen. Dennis DeConcini     Appropriations Committee   
                                (AZ) See also Nevada                                
Delta states  88-94   1,875      See Mississippi &                                  
Hawaii        87-94    1680    Representative (later     House Ag Subcommittee of   
                               Senator) Daniel Akaka     Appropriations Committee   
Illinois         94      50  Representative Rich Durbin  Ag Subcommittee of         
                                                         Appropriations Committee   
                               Representative Sidney     Appropriations Committee   
Louisiana      1994     450   Senator Bennett Johnston   Ag Subcommittee of         
                                                         Appropriations Committee   
Maine         90-94     375                                                         
Minnesota     87-94   1,110    Representative Collin     Livestock Subcommittee     
                              Peterson Representative    of Agriculture Committee   
                                     Tim Penny           Agriculture Committee      
Mississippi   90-94     900     Senator John Stennis     Ag Subcommittee of         
                                                         Appropriations Committee   
                                Representative Jamie     Ag Subcommittee of         
                                      Whitten            Appropriations Committee   
Montana       88-92     500     Senator Conrad Burns     Appropriations Committee   
                                 Senator Max Baucus      Agriculture Committee      
                                 Representative Pat      Agriculture Committee      
Nevada           94     100      Senator Harry Reid      Appropriations Committee   
                               Representative Barbara    Ag Subcommittee of         
                                     Vucanovich          Appropriations Committee   
New Mexico       94      60   Representative Joe Sheen   Ag Subcommittee of         
                                                         Appropriations Committee   
North Dakota  89-94   3,908   Senators Quentin Burdick   Ag Subcommittee of         
                                  and Mark Andrews       Appropriations Committee   
Northwest     88-94   1,985    Senator Mark Hatfield     Appropriations Committee   
Texas         87-89     900      Senator Phil Gramm      Ag Subcommittee of         
                             Represenative Kika  de la   Appropriations Committee   
                                       Garza             Chair, Agriculture         
Utah          90-92     750      Senator Jacob Garn      Appropriations Committee   
Vermont       88-92     248    Senator Patrick Leahy     Chair, Ag Committee,       
                                                         Appropriations Committee   
Wisconsin     88-94     700    Senator Robert Kasten     Ag Subcommittee of         
                                 (term ended 1992)       Appropriations Committee   
                              Represenative David Obey   Ag Subcommittee of         
                               (joined subcomm. 1991)    Appropriations Committee   

Most of the local earmarks are probably due to specific members of the House or Senate appropriations committees. Since many states are not represented on these committees, this leads to an unfair distribution of funds.

The Kansas Alternative

Kansas offers an example of how animal damage might be handled in many states if the federal program did not exist. Although part of ADC's Western Region, Kansas has not participated in ADC's livestock program for at least 28 years. Instead, the state has stationed one extension agent at Kansas State University to assist farmers with animal damage problems.

The agent, Robert Henderson, estimates that he spends only 60 percent of his time on animal damage problems. He also estimates that his salary, combined with travel costs and administrative overhead, cost the state less than $100,000 per year. This means that Kansas' ADC budget is, effectively, less than $60,000 per year.

Kansas farmers who suffer from livestock predation can turn to Henderson for training on how to trap or kill predators. Henderson may also suggest trappers that farmers can hire. But Henderson does not trap or kill predators himself.

Instead, Henderson encourages farmers to use practices that reduce the risk of predation. Publications that he distributes point to research done at Kansas State which found that penning sheep at night will largely protect them from coyotes.[15]

Nebraska and Kansas are geographically similar and contain similar numbers of cattle and sheep (table twenty). While Nebraska spends four times as much on its ADC livestock program, and kills far more coyotes, farmers in Kansas report fewer losses to coyotes or other predators.

Table Twenty
Comparison of Kansas and Nebraska Livestock Statistics

                       	Kansas   	Nebraska 	K % of N
ADC livestock budget   	   60,000	  243,000	 25%
Budget paid by state   	   60,000	   88,000	 68%
Coyotes killed by ADC  	        0	    2,483	  0%
Private coyote harvest 	    1,800	   16,316	 11%
Cattle herd            	5,700,000	6,000,000	 95%
Calf crop              	1,330,000	1,680,000	 79%
Sheep herd             	  185,000	  135,000	137%
Lamb crop              	  145,000	  125,000	116%
Losses to Predators
Cattle losses          	      200	      200	100%
Calf losses            	    1,100	    1,800	 61%
Sheep losses           	    2,000	    1,700	118%
Lamb losses            	    1,800	    4,600	 39%
Losses to Coyotes
Cattle losses          	      100	      100	100%
Calf losses            	      800	    1,700	 47%
Sheep losses to coyotes	    1,300	    1,500	 87%
Lamb losses            	    1,300	    4,200	 31%
Losses to Predators as Share of Herd or Crop
Cattle losses          	   0.004%	   0.003%	105%
Calf losses            	   0.083%	   0.107%	 77%
Sheep losses           	   1.081%	   1.259%	 86%
Lamb losses            	   1.241%	   3.680%	 34%
Losses to Coyotes as Share of Herd or Crop
Cattle losses          	   0.002%	   0.002%	105%
Calf losses            	   0.060%	   0.101%	 59%
Sheep losses to coyotes	   0.703%	   1.111%	 63%
Lamb losses            	   0.897%	   3.360%	 27%

Kansas has slightly fewer cattle than Nebraska, yet it reports only about two-thirds as many calf losses. With more sheep than Nebraska, Kansas has far fewer lamb losses. The difference in sheep losses to coyotes is even more dramatic: Despite its larger herds, Kansas suffers 13 percent fewer adult losses and nearly 70 percent fewer lamb losses than Nebraska.

Only among adult cattle do the figures show a higher proportion of herd loss to predators in Kansas than Nebraska. But this is probably a result of the way NASS reported its data: all numbers were rounded to the nearest hundred--"200" could be anywhere from 151 to 249. If Kansas' cattle losses to predation were only 180, while Nebraska's losses were 220, then Kansas adult cattle losses, as a proportion of Nebraska's, would be similar to the adult sheep numbers.

Kansas appears even better when compared with its neighbor to the south, Oklahoma. Oklahoma's herds are even closer in size to Kansas' then those of Nebraska. Oklahoma's ADC program is more than twice as large as Nebraska's and nearly ten times as large as Kansas'. Yet Oklahoma farmers suffer nearly five times as much predation as in Kansas.

Kansas is a model of what ADC might look like in many states without the federal program. If the federal program did not exist, then some states such as Texas would probably still have a major ADC program. But many other states may fund ADC only to get federal matching dollars. Without such matching dollars, western livestock growers in many states would have to fund predator control out of their own pockets.

This might lead some to use the least costly methods available to kill coyotes, such as poisons, which might be less environmentally desirable. But others would use alternative practices, such as guard dogs or penning, to reduce the risk of predation. Still others would reduce their herd sizes in response to increased costs, thus reducing the effects of grazing on the land. The net effect would be an improvement for the land, for wildlife, and even for many farmers and ranchers.


ADC costs taxpayers nearly $36 million per year. While this is not the most expensive boondoggle on the federal government's books, it is one that has significant environmental effects and one that clearly benefits just a few special interests.

Fully 40 percent of ADC's budget is directed toward protecting livestock from predators on public lands. Only about 27,000 ranchers have permits to graze livestock on public land. This means that each of those ranchers effectively receive a subsidy from ADC of over $550 per year.

Virtually all of the people who benefit from ADC could do ADC's work themselves. If they had to do so, many would probably use alternate methods, such as spending more efforts protecting their livestock and less indiscriminately killing predators.

The distribution of ADC's programs are inherently unfair. Congressional earmarks favor certain states over others--namely those that have members on the appropriations committees. The livestock program focuses on western states to the near-exclusion of eastern farmers. These inequities are a natural consequence of the pork barrel process and cannot be remedied by, for example, increasing ADC's budget to cover more farmers.

Beyond the waste of money and inequities of the program, this report has shown that the ADC program creates numerous perverse incentives. These include:

In the end, there are two overwhelming reasons for shutting down the ADC program. First, there is no justification for a special USDA animal damage control program. ADC's work is local and should be funded by private interests or, in some cases, state and local governments. If ADC were to disappear tomorrow, most states would probably opt for the Kansas model of educating people rather than the Texas model of spending millions of dollars on a single special interest group.

Second, the existence of ADC creates perverse incentives for farmers, USDA officials, and members of Congress to mismanage public resources--both public funds and publicly owned wildlife. These misincentives cannot be fixed by tinkering with ADC's budget. They will end only when the ADC program itself is ended.


1. USDA, Animal Damage Control Program Supplement to the Draft Environmental Impact Statement (Washington, DC: USDA, 1993), p. 7.

2. Jack Olsen, Slaughter the Animals, Poison the Earth (New York, NY: Simon & Schuster, 1971), 287 pp.

3. Dayton Hyde, Don Coyote--The Good Times and Bad Times of a Much Maligned American Original (New York, NY: Arbor House, 1986), 245 pp.

4. Animal Damage Control Western Region Program Evaluation Panel, An Evaluation of the Effectiveness of the USDA, APHIS Animal Damage Control Program in Protecting Livestock (Washington, DC: ADC, 1993), p. 4.

5. Robert Robel, et al., "Relationships between Husbandry Methods and Sheep Losses to Canine Predators," Journal of Wildlife Management 45(4):894-911.

6. William James Haga and Nicholas Acocella, Haga's Law (New York, NY: William Morrow, 1980), 191 pp.

7. National Agricultural Statistics Service, Cattle and Calves Death Loss (Washington, DC: USDA, 1992), 23 pp.

8. National Agricultural Statistics Service, Sheep and Goat Predator Loss (Washington, DC: USDA, 1991), 12 pp.

9. National Agricultural Statistics Service, Agricultural Statistics 1992 (Washington, DC: USDA, 1992), 524 pp.

10. Ted Williams, "Beyond Traps and Poisons: Can the Agency Charged with Regulating Nuisance Animals Clean Up Its Act?" Audubon, March-April, 1994, pp. 28-34.

11. Edward Corwin, Liberty Against Government (Baton Rouge, LA: LSU Press, 1948), p. 4n.

12. Ibid.

13. USDA, ADC Supplement to the DEIS, p. 3.

14. Ibid, p. 7.

15. Robert Henderson, Managing Predator Problems (Manhattan, KS: KSU Extension, 1980), 19 pp.

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