Approval of this agreement and the annual Work and Financial Plan will allow Wildlife Services to continue to protect residents, property, livestock, crops, and natural resources from damage caused by predators and other nuisance wildlife. The cooperative contract for Yolo County is for one Wildlife Services Specialist position. Yolo County has partnered with Wildlife Services for more than ninety years; this four year Cooperative Agreement will continue the partnership until June 30, 2023.
The cooperative agreement may be terminated by either party upon 90 days written notice to the other party. The cost of the Wildlife Services Specialist is shared between the County, University of California Davis, and the cities of West Sacramento, Winters, and Woodland. Each year USDA will provide a Work and Financial Plan projecting the county's portion of the program costs for the upcoming year.
The County has continuously maintained the IWDM Program in its current form since at least 1924 with a break between 1932 and 1939. It is implemented throughout Yolo County, including incorporated cities (with service limited to technical advice in the City of Davis). Over the past five calendar years (2013-17), the IWDM Program has resulted in the removal of 939 animals, for an average of 188 per year, in response to property and agricultural damage. Animals removed have primarily included beaver (29%) and coyotes (47%), and pigeons, raccoons, skunks, and ground squirrels are also among those commonly removed. Less common animals removed through the IWDM program include feral chickens, pea fowl, feral swine, and opossum (all less than four individuals per year on average). Only a single individual of a special status species (American badger, a species of special concern) was affected by program operations, and it was released after capture. During the past decade, USDA staff has also provided substantial technical assistance to County residents, serving over 5,414 participants at 2,330 events and other points of contact such as calls for advice on the prevention and/or control of wildlife damage to property.
In consultation with the Office of the County Counsel, the Agricultural Commissioner recommends that the Board find the recommended actions to be categorically exempt from the California Environmental Quality Act (“CEQA”) under the following provisions:
1. California Code of Regulations, Title 14, Chapter 3, Section 15061(b)(3) of the CEQA Guidelines, which exempts actions where it can be seen with certainty that there is no possibility that the activity may have a significant effect on the environment.
Analysis: The IWDM Program would not have a substantial adverse effect on the environment, as this program will operate within the bounds of all local, state, and federal laws and USDA will seek regulatory agency approval and applicable permits before the removal of any game, candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations by the California Department of Fish and Wildlife (CDFW) or U.S. Fish and Wildlife Service (FWS).
2. California Code of Regulations, Title 14, Chapter 3, Section 15307, Class 7 (Actions by Regulatory Agencies for Protection of Natural Resources) of the CEQA Guidelines, which exempts actions taken by regulatory agencies as authorized by state law or local ordinance to assure the maintenance, restoration, or enhancement of a natural resource where the regulatory process involves procedures for protection of the environment.
Analysis: The IWDM Program maintains natural resources associated with publically managed parks, lakes, state and national forests, wildlife and fish, (including sensitive, threatened, and endangered species), and wetlands. Natural resource protection includes the protection of natural areas from the impacts of invasive species such as feral swine, the safeguarding of rare, threatened and endangered wildlife species from the negative impacts of more abundant ones, and the provision of information and education on the ecology and values associated with wildlife encountered by the public.
3. California Code of Regulations, Title 14, Chapter 3, Section 15308, Class 8 (Action by Regulatory Agencies for Protection of the Environment) of the CEQA Guidelines, which exempts actions taken by regulatory agencies as authorized by state law or local ordinance to assure the maintenance, restoration, enhancement, or protection of the environment.
Analysis: The IWDM Program maintains, restores, and enhances the environment by protecting threatened and endangered wildlife and plants from the impacts of disease, invasive species, and predators. These activities are conducted in collaboration with FWS, CDFW, and conservation organizations.
CEQA categorical exemptions are subject to certain exceptions (Section 15300.2 of the CEQA Guidelines). For example, a categorical exemption “shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.”
Staff are unaware of any “unusual circumstances” that may be relevant to the application of the foregoing exceptions to the IWDM program. The substantial evidence supporting this determination includes, but is not limited to, the following:
- The Program has been in existence within Yolo County for over 90 years and there is no evidence the Program has had an adverse effect on the environment during this time. Depredation activities have been occurring annually for nearly a century and ceasing such activities would in fact result in a “change” to current conditions, and would impair ongoing efforts to maintain the environment and protect natural resources.
- Over 30 other counties throughout the State operate the same or a similar program and there is nothing unusual about Yolo County’s implementation of the IWDM Program.
- While death and harm to wildlife may be considered by some as “unusual”, all of the wildlife subject to damage management control measures under the IWDM Program in recent years have not been threatened, endangered, or fully protected species under state or federal law and therefore are not protected species for purposes of CEQA. In other words, impacts to non-threatened species such as beaver and coyotes would not be considered significant under CEQA and would not be subject to environmental review. In fact, animal removal is sometimes beneficial to the protection of endangered, threatened and fully protected species. When depredation of individual animals classified as members of sensitive species is necessary, it is done with full compliance of State and Federal “take” procedures to ensure that the species are afforded full protection.
For all of the foregoing reasons, staff request that the Board approve the recommended actions. |