Q & A on Control of Predatory Animals in Wyoming
Part 1
by Donal O’Toole and Michael Palmer
1. What is the history of predator control in Wyoming?
Systematic predator control coincided with the introduction of commercial cattle and sheep operations into the state after the mid-1800s. Initial efforts involved individual ranchers and local groups using strychnine, guns and traps to kill native predators, supplemented by local bounties. In 1869 the Wyoming territorial legislature enacted its first predator control legislation, addressing the use of animal poisons for lacing carcasses with lethal compounds like strychnine. The first state-based legislation involving bounties was enacted in 1873 for the protection of sheep. This comprised a payout of 50c for each wolf killed. By 1893 this had increased to a remarkable $8/wolf carcass – no small sum for its time, and a robust subsidy for Wyoming’s “wolfer”/trapper/ poisoning enterprises. The program duly expanded into bounties for bald and golden eagles, hawks, bobcat, lynx, bear, mountain lion, and coyote.¹ This continued until 1945, when a mill levy was introduced. That in turn changed in 1990, when subsidies for statewide predator control were introduced, which involved a combination of state tax revenue and a headage on individual cattle and sheep as they were sold. Federal involvement in predator control began in 1885. In 1915, Congress first appropriated funds to control wolves and coyotes. It was propelled by an ingenious argument from ranchers, including Wyoming’s Senator Warren: the creation of public lands resulted in protected breeding grounds for predators, despite them remaining accessible to the public, including ranchers. The agricultural lobby successfully argued that federal dollars were now owed to stockgrowers to help address the problem. Congress passed the Animal Damage Control Act in 1931, authorizing funding for lethal control of mammalian predators, rodents, and birds. In 1985, after an inter-departmental tussle, the Animal Damage Control unit (now Wildlife Services – WS) was wrested from the Department of the Interior and restored to the United States Department of Agriculture. Agricultural interests had long wanted federal predator control within the USDA, since this is where animal agriculture had most influence. Private bounties did not disappear entirely once American tax-payers picked up the tab. In our area, a 501(c)(3) trappers’ nonprofit with the innocuous title of the Foundation for Wildlife Management (F4WM) currently offers a bounty of $500–1,000 for each wolf killed in Idaho and Montana. Such bounties are legal in Wyoming but not used.² F4WM’s top stated goals are to “promote wildlife population recovery in areas negatively impacted by wolves [and to] assist state game management agencies in meeting their wolf management objectives.” One of its partners and financial supporters is the Idaho Fish and Game department. F4WM claims it funds 75 percent and 55 percent of all wolves killed annually in Idaho and Montana respectively. That is a total of 2,742 wolves killed to date, at a cost to sponsors and private members of >$2 million. Interestingly, F4WM has yet to establish a foothold in Wyoming.³ This may change should the Trump administration remove federal protections from wolves in the lower 48 states. This is currently proposed in a draft bill called the Pet and Livestock Protection Act of 2025 (H.R.845).⁴,⁵
2. Which species are officially listed as predators in Wyoming?
They are coyote, jackrabbit, porcupine, raccoon, red fox, skunk, stray cat, and – over 85 percent of the state – wolf (gray wolf). Four additional species (black bear; grizzly bear; mountain lion; wolf – in the northeast corner, or 15 percent of the state) are designated “trophy game.” “Predaceous birds” are also targeted. Statutory authority for predator control is delegated to the Wyoming Department of Agriculture (WDA) under chapter 6 (Predatory Animals) of Title 11 (Agriculture, livestock, and other animals): specifically, W.S. 11-6-101 to 11-6-108; 11-6-201 to 11-6-210, and 11-6-301 to 11-6-312.⁶
3. Which agencies and organizations manage predators in Wyoming?
The principal entities engaged with predator control are the Wyoming Animal Damage Management Board (ADMB) operating through county predator management boards in 19 of Wyoming’s 23 counties, and the USDA’s Wildlife Services (WS), which was previously called Animal Damage Control.⁷ The Wyoming Game and Fish Department is required by statute to contribute $200,000 annually to the ADMB’s animal damage management account. In years with heavy winterkill among deer, elk, and pronghorn, this is supplemented by additional sums volunteered by WGFD to kill black bears, mountain lions, and coyotes, with the rationale that this boosts fawn survival.⁸ Its political rationale is that it maintains cordial relations between the department and the ranching and outfitting lobbies.
4. How is predator control funded?
The principal source is a legislatively-approved general fund appropriation (i.e., taxpayers; that’s you and me, babe). It is supplemented by proceeds from a predator fee on cattle and sheep sold in the 19 Wyoming counties with a predatory animal control board. For the 2022–2024 biennium, the Wyoming legislature allocated $5.88 million for predator management, or $2.94 million annually. The predator fee on livestock adds another $1 million per year. WGFD contributes $200,000. Typically, WGFD money is for research and targeted predator-killing efforts to reduce losses in specific populations of mule deer, pronghorn, and sage grouse.
5. What methods of predator control are funded and practiced in Wyoming?
It varies with the species targeted. In Albany County, coyotes and ravens are the main species killed. Most coyotes targeted by state or federal agencies are shot, either from helicopters or planes, or from the ground. M-44 cyanide devices are also used to kill coyotes, red foxes, and other predators.⁹ These were banned by the Bureau of Land Management on BLM lands in 2023, during the Biden administration.¹⁰ Once baited, they work as pressure-activated devices. They shoot a cloud of sodium cyanide powder into the faces of curious animals, ideally coyotes and foxes, and less ideally dogs and – rarely – people. In theory, the ban is expected to remain in place until September 2028. A reversal by the current administration before that time seems likely. Ravens are poisoned using avicides such as DRC-1339 (3-chloro-p-toluidine hydrochloride; Starlicide), delivered via pet food, corn, or livestock pellets.¹¹ The compound is a slow-acting toxicant that kills birds 3–80 hours after ingestion through its nephrotoxic effects.
6. What is the history of the Wolf Trophy Game Management Area in Wyoming, and is it unique to Wyoming?
Wyoming is the only state that created a trophy game management area for gray wolves. It comprises 15 percent of the state. The WTGMA borders the eastern and southern boundaries of Yellowstone NP, and surrounds Grand Teton NP. The goal is to maintain a buffer area between the national parks, where wolves are protected. Over and the rest of the state, where wolves are a listed predator and eligible to be shot, gassed, or poisoned. For wolves to be federally delisted under the Endangered Species Act (ESA) and come under state control, the state of Wyoming committed to keeping wolf numbers at or above a specified minimum recovery level. That number, which the powers-that-be wished to keep as low as possible, was at least 10 breeding pairs and at least 100 wolves.¹³ This number includes wolves inside both Grand Teton NP and the National Elk Refuge. The rest of the state was, somewhat arbitrarily, declared unsuitable wolf habitat due to ranching concerns. Part of the motivation was to ensure that wolves did not naturally recolonize parts of Wyoming from packs that had moved into Idaho in the 1990s. That would have left the state with fewer management options to control wolves (i.e., situations in which it was legal to kill them) under the ESA.
7. How many animals are killed annually by federal, state, and local authorities?
A precise total is impossible to establish. Several agencies are involved, supplemented by the efforts of trappers for hire, ranchers, participants in coyote-killing competitions, and ranch owners who promote coyote hunts on private land. Nationally, in 2023, some 375,000 native wildlife were killed by the USDA’s WS division.¹⁴ That included 305 gray wolves, 68,562 coyotes, 430 black bears, 235 mountain lions, 469 bobcats, 2,122 red and gray foxes, 24,603 beaver, and 14,314 red-winged blackbirds. At least 2,484 animals were killed inadvertently as trap bycatch and by poisoning. Note that in 2019, approximately 1.3 million native animals were killed, compared to the lower number reported for 2023. In 2021, 1.75 million animals were killed by Wildlife Services, including over 1 million European starlings, 143,903 feral pigs, 66,554 pigeons, 63,965 coyotes, 24,683 beaver, and 9,003 white-tailed deer. The lower numbers of native wildlife killed by WS in the most recent year for which we have numbers (2023) was due in part to litigation and community opposition in multiple states.¹⁵ Reasons for killing animals include protecting agriculture industries, protecting endangered and game species, and human health.
(Image courtesy Google and USDA)
— Donal O’Toole is a retired veterinarian and board-certified pathologist. During his career, he worked professionally with animals in Ireland, the United Kingdom, and the United States. He was a professor at the University of Wyoming, where he worked and taught as a diagnostician and research veterinarian for 32 years.
— Michael Palmer worked for 10 years as a college teacher and professor in Colorado and Missouri, and later spent 12 years as an IT administrator at the University of Wyoming. Upon leaving the university, he started a small business and for 24 years wrote books and give presentations on computer networking and computer operating systems. Now retired, he loves outdoor activities including hiking, biking, and watching wildlife.
References
1. Van Nuys F: 2015, Varmints and Victims. Predator Control in the American West. Pp.27-89. University Press of Kansas, Lawrence KS.
2. Foundation for Wildlife Management; https://f4wm.org/; accessed 3/30/2025
3. Koshmrl M: 2022, Wolf-killing group makes a play for Wyoming. Wyofile
https://wyofile.com/wolf-killing-group-makes-a- play-for-wyoming/ 3/23/2022
4. Heinz M: 2025, If Feds delist wolves everywhere, will Colorado’s reintroduction program crash? Cowboy State Daily https:// cowboystatedaily.com/2025/03/28/if-feds-delist-wolves-everywhere-will-colorados-reintroduction-program-crash/ 3/28/2025.
5. H.R.845. https://www.congress.gov/bill/119th-congress/house-bill/845 ; accessed 3/30/2025
6. Wyoming Animal Damage Management Board. Predatory animal control laws, rules, and regulation. https://www.wyadmb.com/ Predator%20Regs%20I.htm ; accessed 3/30/2025
7. USDA APHIS Wildlife Services. https://www.aphis.usda.gov/wildlife-services ; accessed 3/30/2025
8. Koshmrl M.2023, In winter’s wake, lions, bears and coyotes could be in the crosshairs. WyoFile https://wyofile.com/in-winters- wake-lions-bears-and-coyotes-could-be-in-the-crosshairs/ 4 28 2023.
9. Wyoming Department of Agriculture 2012, Using the M-44 in coyote damage control. https://wyominguntrapped.org/wp-content/uploads/2017/04/State-of-Wyoming-m-44-applicators-manual.pdf.
10. Bureau of Land Management, 2024. Discontinuing the use of M-44 devices that deliver sodium cyanide from BLM- managed public lands. https://www.blm.gov/policy/ib-2024-024 2/24/2024
11. Starlicide. https://en.wikipedia.org/wiki/Starlicide ; accessed 3/30/2025.
12. Wyoming Game and Fish Department, Wolves in Wyoming. https://wgfd.wyo.gov/wyoming-wildlife/large-carnivore/wolves-wyoming; accessed 3/30/2025
13. Wyoming Game and Fish Department, 2011 and 2012. Wyoming gray wolf management plan. https://wgfd.wyo.gov/ media/3730/download?inline ; 9/14/2011; and Addendum: Wyoming gray wolf management plan. https://wgfd.wyo.gov/ media/3731/download?inline; 3/22/2012.
14. Center for Biological Diversity, 2024. 375,000 native animals killed by the federal program in 2023. https://biologicaldiversity.org/w/news/press-releases/375000-native-animals-killed-by-federal-program-in-2023-2024-04-03/; 4/3/2024
15. The Guardian, 2022. ‘A barbaric federal program’: US killed 1.75m animals last year – or 200 per hour. https://www.theguardian.com/world/2022/mar/25/us-government-wildlife-services-animals-deaths ; 3/25/2022.