Dear Fellow Mass. PAC Agent:
As you know as per my previous email USDA Wildlife Services (WS) has been actively looking to expand their wildlife control program in direct competition with PAC agents and small wildlife and pest control businesses in Massachusetts. I want to offer an update as to where things are at.
The fight to stop the expansion of Wildlife Services in MA is ongoing. Thank you to everyone who sent comment letters to Wildlife Services and emails to their elected representatives. The good news is our voice is being heard
. Last week many members of our Congressional delegation signed a letter that was sent to USDA Secretary Tom Vilsack in support of our small wildlife businesses here in MA. Please view that letter at: http://www.integratedwildlifecontrol.com/pest-management-letter-jul...
Jennifer Walters, aide to Congressman Jim McGovern - Jennifer.email@example.com
Patrick O’Connor, aide to Congressman Richard Neal - Patrick.firstname.lastname@example.org
Kristin Palmer, aide to Congressman John Olver - Kristin.email@example.com
Charlie Moskowitz, aide to Congressman John Tierney- Charlie.firstname.lastname@example.org
James Gordon, aide to Congressman Stephen Lynch - Jim.Gordon@mail.house.gov
Derek Torrey, aide to Congressman Niki Tsongas - Derek.email@example.com
Kerry O’Brien, aide to Congressman William Keating - Kerry.o’firstname.lastname@example.org
If you’re not sure of who your Congressman is, enter your address on the following website:http://www.contactingthecongress.org/
Below I’ve included a summary of the process to this point.
It is good to note that the Mass. Trappers Association and the newly re-forming Mass. Association of Problem Controllers is standing together on this issue. We look forward to a more cooperative relationship in protecting our common interests from outside threats. Information on MAPAC is forthcoming.
A Review of the Recent History of WS in MA:
When any federal agency is looking to do work in a state, they are required to do an Environmental Assessment (EA) according to the federal National Environmental Policy Act (NEPA). As Wildlife Services is the only federal agency (other than the post office) that operates like a business, their cumbersome 136 page Environmental Assessment also doubles as a business plan which describes the ways in which they will expand their wildlife control services in MA. WS services claims to have a public comment period but the only public notice of their EA was a legal notice in the Boston Herald. Who reads those?
According to the EA between 1996 and 2011 WS trapped 674 large rodents that the EA discusses (beavers, muskrats, woodchucks, and porcupines). That’s 42 animals per year. The EA authorizes the direct control of up to 1600 animals and the construction of up to 100 beaver flow control devices every year. That’s an awful lot of work that this federal agency would be taking away from small businesses in Massachusetts.
As I stated in my previous letter, Massachusetts already has an effective system in place to deal with human-wildlife conflicts including fur trappers and over 150 wildlife control companies overseen by the Division of Fisheries and Wildlife (DFW). When asked directly if the current system that we have in place is working, the DFW Deputy Director said yes.
While WS claims not to advertise and only responds to requests for service, this claim is questionable as they sent a letter soliciting comments to the EA to potential “cooperators” – the WS term for customers. That letter (attached the previous email) is a notice of the availability that WS provides wildlife control services. If a private company sends a letter describing their availability to provide service it’s called direct mail advertising. Also when WS is out providing service, word-of-mouth kicks in as a very strong marketing tool, especially since they’re subsidized.
The EA notification letter was not sent to important wildlife or environmental stakeholders including the Massachusetts Division of Fisheries and Wildlife. As anyone in wildlife control knows when you’re dealing with beavers you’re also dealing with wetlands. Massachusetts has a very strong Wetland Protection Act overseen by local Conservation Commissions and regulated by the Department of Environmental Protection (DEP). And despite the fact that the EA describes the removal of beaver dams (including the use of explosives) and the draining of wetlands, the EA was not sent to DEP or the Mass. Association of Conservation Commissions so that they could comment on WS proposed activities in their jurisdictions. In fact page 112+ of the EA describes the ways in which WS can circumvent local and state permitting requirements.
I recently attended a meeting with WS. The most interesting thing that I noted during the meeting was how determined WS is to expand their program to compete with small businesses in Mass. They described that federal funding for their offices is very low. They said they need to have Cooperative Services Agreements (contracts) and take direct action in wildlife control to provide funds to support their program. One WS staff member said that when he first stated his job his office had 4 full-time employees and 2 part-time employees but “over time the office has grown significantly”. He also said they’re bringing in more cooperator dollars every year.
Remember - even if you do not work with the animals that Wildlife Services is pursuing here - if this initial program goes through, then they could very well go after the rest of the animals listed on your PAC permit. Where would you be then? This is very dangerous precedent they are seeking to set. As small business owners we expect competition. We just didn’t expect from an agency of the federal government that is subsidized by taxpayers and has the deck stacked in its favor.