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Santa Fe National Forest
Forest Plan Revision Team
11 Forest Lane
Santa Fe, NM 87508
Santa Fe National Forest Plan Must Prohibit Trapping
Dear U.S. Forest Service,
The majority of people who recreate in the Caja del Rio, in Santa Fe County, do so to hike, walk and play with their pets, backpack, observe wildlife and birds, camp, breathe fresh air and enjoy its preservation of raw and wild land. What those people should not have to worry about is for themselves, their children, or their pets to be caught and injured in any trap set for fur-bearing wildlife.
Traps are inhumane and indiscriminate. Trap locations are not revealed to New Mexico Game and Fish, Federal agents, or the general public. There is no requirement for trappers to post any signs informing or warning the public of where traps are located so they may protect themselves, their children, or their pets. Although there are mandatory set-back distances from trails, roads, and other human facilities, those rules are not always complied with and pets and non-target animals are often victimized. There is no requirement for reporting animals that are trapped or killed, including domestic pets, therefore there is no limit as to how many animals have suffered or will suffer in the future.
Visiting tourists and the citizens of Santa Fe who are recreating in the Caja del Rio are at risk of injury to themselves and their families. If they happen to be aware of the possibility of traps, they enter the forest with fear and anxiety, never able to fully enjoy the wonders that surround them.
In addition to danger to unsuspecting humans, traps also expose a dangerous threat to non-target animals. Dogs, horses, deer, bear, rabbits, quail, and endangered species are all vulnerable to trapping. All animals caught in traps suffer tremendously from fear, pain, psychological stress, starvation, dehydration, or predation for extended periods of time. Whether they live or die, their experience is inhumane, reflecting the human capacity for cruelty. The Santa Fe National Forest should not be a playground for cruelty or a party to the commercial fur industry.
The citizens of Santa Fe County do not want trapping within the county. Santa Fe County Resolution 2011-25, A Resolution to Support Banning Inhumane Animal Trapping On New Mexico Public Lands Through The Use of Strangulation Snares, Steel-Jaw Traps and Other Body-Gripping Animal Traps, was passed on February 22, 2011. The resolution addresses the lack of discrimination traps have for victims, the location of traps being used, the lack of requirements for marking locations of set traps, the suffering of humans and companion animals, tourism, the declaration by multiple organizations for the traps' inhumane nature, and the benefits for the county for eliminating trapping.
We request that the Forest Service use its statutory ability to close the Caja del Rio and other areas of Santa Fe National Forest that are used by recreationalists to trapping. Title 36, Section 261.50(a), of the Code of Federal Regulations gives the Forest Service authority to issue orders to close or restrict the use of described areas. Section 261.50(a) states, in pertinent part:
The Chief, each Regional Forester, each Experiment Station Director, the Administrator of the Lake Tahoe Basin Management Unit and each Forest Supervisor may issue orders which close or restrict the use of described areas within the area over which he has jurisdiction. An order may close an area to entry or may re- strict the use of an area by applying any or all of the prohibitions authorized in this subpart or any portion thereof.
Further, trapping is a "commercial" industry; it is largely driven by commercial fur industry prices. The primary purpose of trapping is the sale of the raw fur-bearing animal pelt to the commercial fur industry, whether or not it is the trappers' sole livelihood or the intent is to make a profit. Trapping increases as fur prices increase and, subsequently, the number of animals removed from the forest ecosystem increases. Therefore, trapping should require a special use authorization for special use of the National Forest System, allowing for specification of the terms and conditions under which the trapping may occur. In 36 CFR section 252.52, commercial use or activity is defined as any use or activity "(a) where an entry or participation fee is charged, or (b) where the primary purpose is the sale of a good or service, and in either case, regardless of whether the use or activity is intended to produce a profit."
Santa Fe National Forest has the opportunity to lead as a graceful model for respect and cohabitation with our incredible, magnificent wildlife. Santa Fe National Forest has the opportunity to provide a balanced representation of diverse wildlife interests that comes without trepidation from humans and wildlife alike.
Prohibiting the use of indiscriminate traps will ensure public safety and expectations. It will protect individuals, their families, companion animals, wildlife and public trust for our Forest System. It will invite a new generation of compassionate citizens to freely enjoy the Caja del Rio and the Santa Fe National Forest.
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The Mountain Lion Foundation, founded in 1986, is a national nonprofit organization protecting mountain lions and their habitat.
We believe that mountain lions are in peril.
Our nation is on the verge of destroying this apex species upon which whole ecosystems depend. Hunting mountain lions is morally unjustified, and killing lions to prevent conflicts is ineffective and dangerous.
There is a critical need to know more about the biology, behavior, and ecology of mountain lions, and governments should base decisions upon truthful science, valid data, and the highest common good. Conserving critical lion habitat is essential.