A Nevada coyote - image - Nevada Department of Wildlife

Reno – On May 8 of this year, the Western Environmental Law Center issued a press release about an analysis they did on public comments made on the proposed reauthorization of sodium cyanide use in the M-44 ejector device. The M-44 is pounded into the ground and baited with a smelly lure and intended to kill animals that prey on livestock or endangered species. When an animal tugs on the bait, the spring-loaded device delivers a lethal dose of sodium cyanide into the animal’s mouth; the animal dies within 1 to 5 minutes.

The United States Department of Agriculture’s Wildlife Services is the only agency licensed by the Environmental Protection Agency to use sodium cyanide in the M-44. Primary targets of the M-44 include coyotes, feral (wild) dogs, and red and gray foxes. 0f the 4,662 coyotes Wildlife Services killed in Nevada in 2017, M-44s killed 262 of them.

The device is controversial. In Idaho, an M-44 temporarily blinded a child and killed three family dogs in two incidents in 2017.  That same year, an M-44 set in Oregon accidentally killed a wolf. In response, Idaho maintains a moratorium on M-44 use on public lands, and earlier this month, Oregon passed legislation banning them in the state. The results of the Western Environmental Law Center’s public comment study were almost entirely opposed to the use of the M-44.

In response to a request for comment, the USDA directed Nevada Capital News to their web pages.

The mission of USDA APHIS Wildlife Services (WS) is to provide Federal leadership and expertise to resolve wildlife conflicts to allow people and wildlife to coexist. WS conducts program delivery, research, and other activities through its Regional and State Offices, the National Wildlife Research Center (NWRC) and its Field Stations, as well as through its National Programs.

Program biologists apply the integrated wildlife damage management approach to provide technical assistance and direct management operations in response to requests for assistance. WS NWRC research scientists are dedicated to the development of wildlife damage management methods.

WS’ mission is to provide Federal leadership among the wildlife management profession, the public, nongovernmental organizations, and governmental/ research entities to address wildlife-related problems in a science-based manner that is both accountable and transparent.

Wildlife Services conducts research in the management of wildlife at its research center in Fort Collins Colorado. Wildlife Services operates the National Rabies Management Program and also works to control numbers of particularly damaging feral swine. According to the Wildlife Services web pages, “Wildlife Services abides by the National Environmental Policy Act by evaluating the environmental impacts of its program activities.”

In Nevada, Wildlife Services manages wildlife populations near Nevada airports to prevent animal/aircraft interactions. They also work at the behest of ranchers and potentially businesses like golf courses or fish hatcheries to prevent “damage” from native and invasive species.

Wildlife Services publishes an annual database of animals taken in the nation. In Nevada, the data for “Animals Dispersed / Killed or Euthanized / Removed or Destroyed / Freed or Relocated” reveals Wildlife Services variously killed 15,618 animals and dispersed 73,744 in Nevada in 2017. Here are a few data points from Nevada in 2017.

Mountain Lions

Five Mountain Lions were killed by neck snare. Two died in foothold traps.


3,872 ravens were killed using poison bait
3,750 mourning doves killed with guns, 14,727 dispersed
5 bufflehead ducks were shot and killed
10 gadwall ducks were shot and killed
106 mallard ducks were shot and killed
186 house finches were shot and killed
217 Canadian geese were shot and killed
17 red-tailed hawks shot and killed
5 great blue herons were shot and killed
90 horned larks shot and killed
49 meadowlarks shot and killed
352 feral pigeons shot and killed

2017 Unintentional Deaths

2 bobcats
1 pronghorn sheep died in a foothold trap
1 wild turkey died in a foothold trap


Estimates indicate as many as 100,000 coyotes live in Nevada, though the actual number is unknown. Nationwide, Wildlife Services killed 68,913 coyotes in 2017.

In Nevada in 2017:

519 coyotes were killed with firearms
2,456 coyotes killed from “Fixed Wing” aircraft
37 coyotes were killed with Gas Cartridge, Large, APHIS-Only
660 coyotes killed from a helicopter
262 coyotes were killed by M-44 Cyanide Capsules
159 coyotes were killed by neck snare
569 coyotes died in foothold traps

4,662 coyotes died in Nevada in 2017.

Nevada Capital News requested information from the USDA regarding the specific reasons for using the M-44. We also asked where they were used in Nevada and if there is a map, but the USDA public information officer has yet to respond.



Efforts to ban the use of the M-44 have been rebuffed. In November of last year, EPA denied a 2017 petition authored by the Center for Biological Diversity and WildEarth Guardians that asked for a nationwide ban on M-44s.

In February of this year, the Environmental Protection Agency released a proposed decision to renew the use of sodium cyanide in the M-44 ejector device.  To learn more about the  M-44 and associated public comment analysis, Nevada Capital News spoke with Collette Adkins, carnivore conservation director and a senior attorney at the Center for Biological Diversity.

“People and their pets, endangered wildlife have all been harmed or even killed by these devices,” Adkins said by phone. “What we’ve seen is that the public is just overwhelmingly and increasingly becoming frustrated that the EPA continues to allow their use. So what we did is took a look at the most recent public comment period that the EPA opens on its proposed decision to renew the registration of this poison (sodium cyanide). More than 22,000 people submitted comments, and what we found is only 10 commenters wanted M-44s to continue to be registered. Ninety-nine point nine percent of the people that commented asked the EPA to stop allowing the use of the cyanide bombs. And what we hope that this does is convince the EPA that these devices are just too dangerous and too ecologically harmful to be used anymore.”

There is no published time-frame for the EPA to decide on the use of sodium cyanide in M-44s. We asked Adkins if there are political and economic factors that come to bear while the EPA deliberates.

“They absolutely are affected by the big money that the pesticide industry has and by economic interests in general,” Adkins said. “So unlike the Endangered Species Act, which requires decisions to be made based on the best available science, FIFRA (The Federal Insecticide, Fungicide, and Rodenticide Act), the pesticide registration statute, allows the consideration of economics and only would ban the reauthorization of a pesticide if the EPA finds that it poses an unreasonable risk to the environment.

“And when it weighs whether something is reasonable or not, it considers the economic benefits of it too. So if the EPA decides to give high weight to the livestock industry’s concerns that they want to be able to use these devices to protect their livestock, then the EPA would go ahead and finalize its registration decision,” Adkins said. “This really is a value-based decision. That’s how to value something like the death of an endangered species, or the loss of a beloved pet or the risk of people against the profits of the livestock industry.”

Little is known about the decision making process behind the use of M-44s.

“There is very little understanding about how these decisions by Wildlife Services are made,” said Adkins. “They do publish annually. I call it their kill data, basically, where they show how many animals in each state and by what method are killed. In Nevada, for 2017, which is the most recent data that’s been posted. This shows that 262 coyotes were killed by M-44s in Nevada. Across the country, the millions of animals that are killed by Wildlife Services are killed entirely on behalf of livestock industry.”

Part of the mission of Wildlife Services is research, but Collette Adkins argues that Wildlife Services policies need to catch up with the latest science.

“And there’s certainly some legitimate uses and activities of Wildlife Services. They help protect public safety at airports, for example. And they can help ranchers with use of non-lethal methods that could prevent conflict with between wildlife and livestock,” said Adkins. “But our biggest complaint is that this is a program that is based on those decades old mentality that the only good carnivore is a dead one. Whenever there’s a conflict, they go ahead and kill the animal. And what we know from the science, and really in terms of public values, that there’s better ways of dealing with these conflicts. It’s better to try to prevent the conflict than just simply kill the animal, which is really just a band-aid because other animals will reproduce and come back to that territory. It’s only when the rancher actually changes its practices. So for example, having guard dogs or putting in motion sustained lights that would scare away predators. It’s only when they actually make these substantive changes that we see these long term changes in their conflict rates.”

Collette Adkins and others concerned about the use of M-44s are hopeful public scrutiny and involvement will eventually change the culture at Wildlife Services and EPA regarding the use of M-44s.

“I think a lot of it is just that this is the way it’s always been done. And that it’s only when the public really speaks out against this that we can really start to force the cultural change in the agency. And we’re starting to see that. A few weeks ago, Oregon banned the use of cyanide bombs statewide. There’s other states like California and others abroad. We’ve seen temporary bans in Idaho and Colorado, for example. So once these bans come in place, the agency turns to other methods,” Adkins said. “There’s lots of other legal methods, so they just turn to shooting an animal which at least is much more likely to hit the actual target than a cyanide bomb that just goes off by anything that pulls on it. But what I’d really like to emphasize is that there’s just so many more effective methods, both cost effective, and effective in terms of preventing the conflict. The science really is clear, but these practices haven’t caught up to it.”

Killing coyotes does not ultimately diminish their numbers.

“What we’ve seen with coyotes, which are really entirely targeted animals by Wildlife Services, legal control just can’t, can’t stop the conflicts because in response to exploitation, the coyotes that remain end up having larger litter sizes. They disperse right back into the territories that are left open by the ones that died.  Wildlife Services has worked, put millions of dollars into killing coyotes across the country, and there’s more than ever,” Adkins said. “Coyotes are extremely resilient animals. And the only way you’re going to be able to stop these conflicts is by preventing  them. It’s not just shooting an animal.”

Pat Jackson is the predator management staff specialist for the Nevada Division of Wildlife. He monitors and variously manages animals like mountain lions, bears, coyotes, ravens, and even grey wolves if they appear in the state.

Ravens are a curious addition to a list of fur-bearing carnivores. “They’re certainly a generalist omnivore,” Jackson said. “But they are a native species that are functioning like an invasive one. There are substantially more ravens on the landscape and pre-colonial settlement because of various human subsidies across the landscape. So they’re in my world. They’re problematic with greater sage grouse nest access, but they also wreak havoc on desert tortoise and long list of others.”

Coyotes are the most widely distributed animal in Nevada, from the state’s remotest and mountainous regions to Reno and Las Vegas. Despite ongoing and robust efforts to curb their numbers, the coyote is as present as it has ever been. For Jackson, coyotes are part of the state’s native environment and cause few problems excepting human and pet interactions with urban coyotes, especially in Las Vegas.

“They are native, and I don’t have any evidence that their populations are increasing,” Jackson said. “Certainly we see issues with urban coyotes increasing consumption of pets, sightings during the day, and particularly Las Vegas and in Reno. But that’s about it.”

The Nevada Division of Wildlife does not kill coyotes in defense of livestock. According to Pat Jackson, the state does not consult with Wildlife Services when it deploys M-44s.

“Coyotes do cause issues for livestock, primarily, domestic sheep, secondarily, cattle, particularly during the calving season, and that’s not a responsibility of NDOW’s. That’s shouldered either privately from the ranchers or they can work with Wildlife Services,” Jackson said.

Wildlife Services says it assesses the environmental outcomes of its actions in accordance with the National Environmental Policy Act, but Collette Adkins questions the environmental and ecological impacts of taking such a wide variety of species.

“I am just so heartbroken and saddened to think of all the suffering that happens at the hands of Wildlife Services,” Adkins said. “I mean, song birds, all these different carnivores are incredibly ecologically important. Even odd things like turtles or vultures. There’s so many different species killed by Wildlife Services. Now we do know that probably animals are killed at airports and that’s likely where a lot of the song birds are being killed.”

As is well known, bird strikes can take down aircraft, so Wildlife Services works to “prevent damage” at airports across the nation, but the agency also works in a wide variety of situations.

“In terms of the water birds, sometimes Wildlife Services kill animals at aquaculture facilities or fish hatcheries,”Adkins said. “Golf courses oftentimes contract with Wildlife Services to kill geese, and it is surprising how many species are targeted by the agency.”

For Adkins, progress is grudging, but persistence may be paying off for Adkins and others working to ban the use of the M-44.

“The Center for Biological Diversity did file a lawsuit in 2017 that challenged the Fish and Wildlife Service’s failure to look at how cyanide bombs and M-44s impact endangered wildlife. And luckily, as a response to that lawsuit, the Fish and Wildlife Service has agreed to do a comprehensive analysis of the impacts of M-44s on endangered wildlife. You can think of, for example, endangered wolves that could just as easily pull on these devices as a targeted Coyote. We’re hopeful that after the Fish and Wildlife Service completes this analysis, that the EPA will have no choice but to ban the devices because they’ll see that the risk to endangered wildlife is just too high.”