The Rewilding Institute Comments on Gray Wolf Delisting and Peer Review

TRI Comments on Gray Wolf Delisting and Peer Review

Originally published March 25, 2014 - The Rewildlige Institute

Attn: FWS–HQ–ES–2013–0073

Division of Policy and Directives Management
U. S. Fish and Wildlife Service
4401 N. Fairfax Drive MS 2042-PDM
Arlington, VA 22203

The Rewilding Institute (TRI) appreciates the opportunity to comment on: Endangered and Threatened Wildlife and Plants; Removing the Gray Wolf (Canis lupus) From the List of Endangered and Threatened Wildlife and Maintaining Protections for the Mexican Wolf (Canis lupus baileyi) by Listing It as Endangered and the peer review of that document.

ACTION: Proposed rule; notice of availability and reopening of comment period.

These comments have been prepared by TRI’s Carnivore Conservation Biologist, David R. Parsons. Mr. Parsons served as the U.S. Fish and Wildlife Service’s (FWS) first Mexican Wolf Recovery Coordinator from 1990-1999 and was the primary author of the original rule that established a Nonessential Experimental Population of the Mexican Gray Wolf in Arizona and New Mexico. Mr. Parsons has continued to follow the progress of the Mexican wolf recovery program from his retirement from FWS in 1999 to the present day. Mr. Parsons holds B.S. and M.S. degrees in Wildlife Biology, served as a career wildlife biologist for FWS for 24 years, and has lectured nationally and internationally on wolf biology, ecology, and conservation.

We remain concerned about ongoing and potential further delays by the FWS in advancing the conservation and recovery of the critically endangered Mexican gray wolf (Canis lupus baileyi).  The FWS has acknowledged that at even the currently authorized population objective of 100 wolves in the Blue Range Wolf Recovery Area (BRWRA), Mexican wolves will remain in danger of extinction.  At a most recent population estimate of only 83 wolves with deleterious levels of inbreeding, Mexican wolves need aggressive recovery actions immediately.

Currently, the proposal to list Canis lupus baileyi as an endangered subspecies is an integral part of the proposal to remove all other presently listed gray wolves (Canis lupus) within the United States from the list of endangered species, and thusly end their protection under the Endangered Species Act (ESA).

A FWS-initiated peer review has concluded that the science that the FWS relied upon to support their proposal to delist gray wolves is not the best available science.  This makes the proposed delisting of gray wolves in violation of the ESA mandate that decisions made pursuant to the ESA be based on the best available science.

Given that FWS has reissued for a second public review the exact same proposal found by the peer reviewers to be scientifically deficient, it is not clear if FWS plans to make any substantive changes to the proposed delisting rule before issuing the final rule.  We are assuming here that FWS will either (1) issue the final delisting rule without substantively addressing the scientific deficiencies found by the peer reviewers, or (2) further delay the release of a final rule to allow FWS biologists time to address the scientific deficiencies found by the peer reviewers.  Either scenario will have adverse consequences for the critically endangered Mexican gray wolf as we explain below.

We note, however, that the peer reviewers and the FWS are in agreement that Canis lupus baileyi is a unique and taxonomically distinct subspecies of Canis lupus deserving of separate protection and recovery actions under the ESA.  And in fact, FWS has proposed the separate listing of the Mexican wolf within this proposed rule.  The only disagreement between the peer reviewers and the FWS is over the probable historic range of the Mexican wolf.  This disagreement is essentially rendered moot by language in the proposed list rule declaring Mexican wolves to be endangered “where found.”

Disagreement over the extent of the Mexican wolf’s historic range is best addressed by the Mexican Wolf Recovery Team using the best available science and settled in a final Mexican Wolf Recovery Plan, not in this proposed rule.  The work of the Mexican Wolf Recovery Team, suspended since November 2011, needs to be resumed immediately.  While not procedurally necessary, it appears that FWS is waiting for the promulgation of the final rule placing Mexican wolves on the endangered species list before resuming work of the recovery team.

History has shown that proposals by the FWS to remove gray wolves from the endangered species list have always been litigated, often delaying or even reversing actions proposed by the FWS.  And history has shown that the FWS tends to suspend legitimate recovery actions for Mexican wolves in the face of litigation over proposals related to other gray wolves.

Furthermore, there is no scientific disagreement over the FWS’s proposal to list Canis lupus baileyi as an endangered subspecies of the gray wolf.  And Mexican wolves are in critical need of recovery actions that are hampered by current regulations and the lack of a current recovery plan based on the best available science (see comments submitted by TRI on the draft proposed rule for Mexican wolves dated 10/24/2013 and incorporated in their entirety here as Appendix A of these comments).

Therefore, to enhance the likelihood of survival and recovery of Mexican wolves, it follows that FWS must decouple the proposal to list Canis lupus baileyi from the proposal to delist gray wolves elsewhere.  No legitimate purpose is served by continuing link these two distinct actions into one combined process that is destined to be litigated solely over the gray wolf delisting part of the proposal.

As for the proposal to delist Canis lupus, TRI recommends that the FWS honor the independent peer review process and base its final decision on the best available science.

As for the proposal to list Canis lupus baileyi TRI recommends that FWS issue an expedited final rule completing this action separate from the gray wolf delisting proposal.  And we further recommend that the existing Mexican Wolf Recovery Team be reactivated immediately with a goal of completing a science-based recovery plan as soon as possible.

As always, The Rewilding Institute appreciates this opportunity to comment on these proposals.

Sincerely,

David R. Parsons
Carnivore Conservation Biologist

PLEASE CLICK HERE TO READ THE ENTIRE DOCUMENT, INCLUDING APPENDIX A

- Read more . . .  

The NRDC's Non-Lethal Methods to Prevent Conflicts Between Predators and Livestock

Every year, the U.S. Department of Agriculture's Wildlife Services program kills thousands of predators as a taxpayer-funded subsidy to the livestock industry, using controversial and inhumane methods such as poisons and aerial gunning. Wildlife Services largely ignores the many non-lethal ways to prevent conflicts between predators and livestock. In fact, a small, but growing number of ranchers are turning away from Wildlife Services’ “sledgehammer” approach and emphasizing non-lethal conflict-prevention techniques because they recognize that predators are an integral part of the landscapes where they ranch.

Wildlife Services needs to end the use of inhumane, hazardous, and environmentally harmful poisons—specifically, Compound 1080 and sodium cyanide—to kill predators. Instead, the agency should employ non-lethal conflict prevention methods. Specifically, Wildlife Services, and the private parties it assists, should be required to use, or attempt to use, nonlethal deterrence methods before resorting to lethal control. 

Click here to download more information 

about non-lethal methods from the NRDC.

Support the NRDC

The North American Model of Wildlife Conservation

By Boone and Crockett Club

Natural resources, including wildlife represent the health and wealth of a country and its people. We are fortunate in North America to have a proven system that not only recognizes these values, but also provides for and directs the proper use and management of these resources.

The North American Model of Wildlife Conservation is anchored by a Supreme Court decision that decreed that wildlife belongs to the people, and not government, corporations or individuals. It further directs how this natural resource is to be used and managed under sustainable guidelines for the betterment of wildlife and people. It is the reason why we still have abundant, wildlife populations in the U.S. and Canada and the opportunity to freely hunt, fish or enjoy this wildlife each in our own way.

The Model is guided by seven principles. It developed over time out of necessity to reverse the negative effects from the unregulated over harvesting of many species of wildlife and early attitudes that these resources where there for the taking and inexhaustible. Sportsmen and women, led by the efforts of the Boone and Crockett Club and its members helped to either establish, popularize, mobilize support for, and/or defend each of these guiding principles over the past 125 years. The results are unprecedented in the history of mankind.

In the Public Trust – Wildlife belongs to the people and managed in trust for the people by government agencies.

Who owns wildlife was determined by a Supreme Court decision at the time the New World was flexing its new independence from European rule. The Public Trust Doctrine is the pillar of North American conservation, but it took time for citizens to fully understand the responsibilities that came with this ownership.

Many of the Boone and Crockett Club’s early efforts were focused on awakening the people to the plight of their wildlife resources, and that these resources did indeed belong to them, and were in their care. These efforts were in concert with the conservation laws the Club and its members were proposing to aid in the recovery and protection of wildlife. Once the public realized it was their wildlife being irresponsibly eliminated their outcry was so great that conservation legislation passed with ease.

Prohibition on Commerce of Dead Wildlife – It will be illegal to sell the meat of any wild animal in North America.

The harvesting wildlife for commercial markets contributed greatly to the extinction of some species of wildlife, and the near extinction of others. With the Boone and Crockett Club rallying the public and political support needed, Club member Senator John F. Lacey of Iowa was able to present and pass the Lacey Acts of 1900 & 1907, which prohibited a commercial value to wild game meat, spelling the end of market hunting, allowing our wildlife to recover and flourish.

Allocation of Wildlife is by Law – Laws developed by the people and enforced by government agencies will regulate the proper use of wildlife resources.

The mere presence of man on the landscape can negatively affect wildlife and the habitats that support them. The rule of law instead of the rule of chance will be used to govern the appropriate use of these wildlife resources.

The Boone and Crockett Club proposed laws and rallied public support for these new rules of order. The Club helped establish government agencies like the U.S. Fish & Wildlife and National Forest Services that were needed to oversee the proper execution and enforcement of these laws. The Club’s Fair Chase statement also became the cornerstone for game laws established by the states.

Opportunity for All – Every citizen has the freedom to hunt and fish.

Public access to wildlife, regardless of social or economic status, including hunting, fishing, and trapping is a right of citizenship. This access fosters individual stewardship and provides the funding necessary to properly manage wildlife resources in a sustainable manner.

Boone and Crockett Club founder, Theodore Roosevelt believed strongly in wise-use conservation and fought aggressively against preservationist, or non-use proposals. The Club also believed that those who use the resource should pay for its care and maintenance. The Club lobbied for the laws and institutions that provided this funding, including a federal excise tax on sporting arms and ammunition and the federal Duck Stamp program. Sportsmen ands women subsequently stepped forward and gladly accepted their role in funding conservation

Non-frivolous Use – In North America we can legally kill certain wildlife for legitimate purposes under strict guidelines for food and fur, in self-defense, or property protection. Laws are in place to restrict casual killing, killing for commercial purposes, wasting of game, and mistreating wildlife.

The rules of proper use, both in written law and personal ethics, did not exist in commercial market and sustenance hunting cultures. As these activities faded, what remained was recreational, sport hunting. What separated a true sportsman from market gunners was an ethical code of personal conduct that was defined and promoted by the Boone and Crockett Club. These same tenets of Fair Chase were used as the cornerstone of modern-day game laws. Club member, Aldo Leopold is credited with framing the concept of a land ethic and managing entire biotic communities. Combined, the foundations for the proper use of The intricate nature of ecosystems and biotic communities, of which all wildlife and man belong, will be managed under the knowledge of science rather than opinion, or conjecture.

wildlife and the habitats that support them was put in place to support conservation, defined by Club member, George Bird Grinnell as,” wise use without waste.”

International Resources – Because wildlife and fish freely migrate across boundaries between states, provinces, and countries they are considered an international resource.

The proper management of certain species of migrating wildlife is to be managed by international treaties and laws.

Sportsmen where among the first to recognize the need for international treaties and laws to save what was left of decimated waterfowl populations.  Wildfowl that nested in Alaska, Canada and the Lower 48 States, and then migrated as far south as Mexico, could only be saved if restrictions to the loss of their wetland nesting habitats and hunting reached across international boundaries.  The Boone and Crockett Club responded with the establishment of the National Wildlife Refuge system (1903) and the passage of the Migratory Bird Act of 1913 & 1917, the Reclamation Act of 1902, and the Migratory Bird Conservation Act of 1929 all contributed to the recovery and future prosperity of migratory species.

Managed by Science – The best science available will be used as a base for informed decision making in wildlife management.

The intricate nature of ecosystems and biotic communities, of which all wildlife and man belong, will be managed under the knowledge of science rather than opinion, or conjecture.

Boone and Crockett Club founder, Theodore Roosevelt was a strong advocate of science, and that only the best science available was to be used to make critical decisions on natural resource management. The Club began by providing seed money for some of the first wildlife research projects. Under the leadership of member, Aldo Leopold the Club began formulating flexible scientific management policies for wildlife and natural resources to achieve an ecological balance. The Club also called for the first President’s Conference on Outdoor Recreation, which lead to the establishment of the National Recreation Policy, which coordinated resource management at federal, state, and local levels.

 

EXPOSED - USDA's Secret War on Wildlife

By Darryl Fears, Published: December 15
Washington Post

They say U.S. critter assassins work in secret, quietly laying traps, lacing food with poison, sniping at targets from helicopters. Few people know exactly how the hits go down; the methods are largely hidden.


What’s certain is that the U.S. Department of Agriculture’s little-known Wildlife Services program kills up to 3 million animals a year, mostly those deemed a nuisance but also some that agents kill by mistake, including endangered species.


Now, in a turnabout, the hunter is the target. A petition seeks to reduce the power of Wildlife Services and shine a light on its practices, claiming its agents have “gone rogue,” overstepping the mission to protect the public by killing indiscriminately.


There’s no dispute that Wildlife Services plays a valuable role by eliminating invasive animals such as nutria and starlings that are a menace. But critics have questions: How many is too many? Does the agency euthanize wildlife too often on behalf of farmers and ranchers without regard to ecosystems?


The petition filed in December of 2013 by the Center for Biological Diversity isn’t the first time that animal rights activists have squared off against Wildlife Services, but this time their coalition includes politicians who agree that the agency is too secret and too deadly. Even some federal workers frown on it; staff members at the U.S. Fish and Wildlife Service quietly dismiss Wildlife Services agents as “gopher chokers.”


“Wildlife Services is one of the most opaque and obstinate departments I’ve dealt with,” said Rep. Peter A. DeFazio (D-Ore.). “We’re really not sure what they’re doing. I’ve asked the agency to give me breakdowns on what lethal methods they’re using. They can’t or won’t do that. We’ve asked them to tell us what goes into their poisons. They won’t say.”


DeFazio and several colleagues requested a congressional hearing on the agency’s practices without success, so they pushed the USDA inspector general to conduct an audit, which was announced this month.


“The WS program is inefficient, inhumane and in need of a review,” the lawmakers wrote in a September letter to Inspector General Phyllis Fong. They said that the frequent killings of top predators, such as wolves, bears and coyotes, benefit “a small proportion of the nation’s private agriculture” and other interests.

Wildlife Services said in response that it has nothing to hide. Answering questions by e-mail, a spokeswoman said that the bulk of its work is to protect humans.

“For example, we work with the aviation community to protect the public by reducing wildlife hazards at more than 800 airports around the country,” spokeswoman Lyndsay Cole said. “Wildlife Services’ efforts to protect threatened and endangered species are conducted in more than 34 states. Wildlife Services also operates the National Rabies Management Program, which distributes oral vaccines in 16 states.”


Read more . . . 

Hunters are conservationists? Maybe many years ago . . . not today.

By Georger Wuerthner - The Wildlife News - March 5, 2014

Many hunter organizations like to promote the idea that hunters were the first and most important conservation advocates. They rest on their laurels of early hunter/wildlife activist like Teddy Roosevelt, and George Bird Grinnell who, among other things, were founding members of the Boone and Crocket Club. But in addition to being hunter advocates, these men were also staunch proponents of national parks and other areas off limits to hunting. Teddy Roosevelt help to establish the first wildlife refuges to protect birds from feather hunters, and he was instrumental in the creation of numerous national parks including the Grand Canyon.  Grinnell was equally active in promoting the creation of national parks like Glacier as well as a staunch advocate for protection of wildlife in places like Yellowstone. Other later hunter/wildlands advocates like Aldo Leopold and Olaus Murie helped to promote wilderness designation and a land ethic as well as a more enlightened attitude about predators.

Unfortunately, though there are definitely still hunters and anglers who put conservation and wildlands protection ahead of their own recreational pursuits, far more of the hunter/angler community is increasingly hostile to wildlife protection and wildlands advocacy.  Perhaps the majority of hunters were always this way, but at least the philosophical leaders in the past were well known advocates of wildlands and wildlife.

Read more . . . 

A Guide to Addressing Wolf-Livestock Conflicts: Non-Lethal Control Methods

Washington State Department of Fish & Wildlife

Non-Lethal Wolf Control Methods

Although wolves mostly prey on elk, deer, and moose, some will attack livestock or scavenge on carcasses. Many non-lethal strategies have been developed to protect livestock from wolf predation and WDFW provides assistance to adapt them to individual producer situations.

WDFW currently provides this kind of assistance, with support from U.S. Fish & Wildlife Service, U.S.D.A. Wildlife Services, U.S. Natural Resource Conservation Service, U.S. Forest Service and other state and federal agencies and grazing land managers.

Assess where and when
The livestock you manage, and where they reside when, are important to consider for reducing the potential for problems with wolves.  Assess, and perhaps change, where and when to turn out livestock of what age and type.

The type, age and number of livestock you manage is key. Sheep, goats and calves are the livestock most commonly attacked by wolves; adult bulls, cows, and horses are less at risk.

The location, size, and accessibility of your calving/lambing areas, feedlots, grazing sites and pastures may dictate your level of risk. Livestock ranges that are remote or in rugged terrain make it harder for stock owners and managers to observe animals and detect wolf-livestock conflict situations. Changing grazing sites temporarily may be necessary to avoid conflicts with wolves while they are at pup-rearing dens or rendezvous sites.

Remove attractants
Wolves don’t just hunt live animals; they also feed or scavenge on already dead animals. To minimize this attraction to wolves and other scavengers, whenever possible, dispose of all dead animals by rendering, burying, or burning in an appropriate and safe manner. Maintain a carcass pit at least eight feet deep with fencing that discourages scavengers. While tending to sick and injured livestock, consider temporarily removing them from the rest of your herd. These animals can be particularly vulnerable to wolves.

Use pens, fencing, fladry
Confine cows and ewes to fenced or barnyard areas during calving and lambing season. Keep calves and lambs in secure pens until they grow larger. Delay the turnout of cattle from fenced areas to open, remote grazing areas until calving is complete, or until deer fawns and elk calves are born, usually early June.

Use permanent or portable fencing, especially for night protection of flocks or herds. Electric fencing has been effective against wolves. Even more effective is the use of “fladry,” a series of bright (usually red or orange) cloth flags hung at 18-inch intervals along a rope or fence line. Wolves are reluctant to cross this barrier. Combining electricity with fladry – “turbo-fladry” – is best, teaching wolves that bite at the flags to stay away.

“Bio-fencing,” using wolf scat and urine to mark a protective “territory” around livestock, is another alternative currently being tested for effectiveness.

Guard with dogs and people
The frequency and intensity of livestock supervision provided can be critical because wolves are territorial and tend to avoid humans.

Use livestock guarding dogs with a herder or shepherd for sheep and goat protection, or near confined livestock of any kind. Specific breeds such as Anatolian shepherds, mastiffs, and Great Pyrenees can be effective, particularly when paired with people. Note that it is important to keep guarding dogs away from active wolf den sites to avoid conflicts with wolves protecting pups.

Increase the routine presence of humans in and around your livestock. Increasing the frequency of herders or range riders monitoring livestock on open range can add protection from wolves. Wolves tend to stay away from areas where there is regular or frequent human presence.

Use Hazing/Scaring Devices
Light and noise “scare” devices can be used to frighten wolves away from confined livestock and alert herders to the presence of wolves. Using non-lethal munitions – including propane cannons, cracker shells, rubber bullets, paintballs and beanbags – to haze wolves near livestock can be effective. The use of these tools must be done in coordination with WDFW and federal authorities.

The radio collars that are on some wolves for monitoring by WDFW can also be used to trigger Radio-Activated Guard (RAG) systems that emit flashing lights and loud sounds at the approach of the radio-collared wolf.

Wolf Expert Doug Smith on the Yellowstone Wolf Project

In this Web-exclusive video, wolf expert Doug Smith discusses the Yellowstone Wolf Project. Started in 1994, the Wolf Project has taken advantage of the visibility of Yellowstone’s wolves to explore wolf population dynamics. Of particular interest is how wolves interact with prey and scavenger populations in the park. Smith hopes that Wolf Project research can help replace common misconceptions about wolves with factual information.

The wolf that changed America

The Reintroduction of Wolves Into Yellowstone

Greater Yellowstone Coalition - WOLVES from GYC on Vimeo.

.

Nearly 1,650 wolves roam the Northern Rockies, in 250 packs with more than 110 breeding pairs. About 500 call Greater Yellowstone home and an estimated 80 wolves live within Yellowstone National Park.

GYC continues to monitor wolf numbers in Greater Yellowstone. Meanwhile, Yellowstone wolves are still playing their ecological role.

A report from Oregon State University plant researchers William J. Ripple and Bob Beschta reinforces the belief that the wolf has been the primary factor in the improved health of aspen, willow, and cottonwood trees in Yellowstone National Park's Northern Range. This in turn has benefitted such Yellowstone wildlife as beaver, bison, pronghorn, songbirds, raptors, and trout.

The return of the wolf has changed elk behavior and reduced some herds, but overall numbers remain strong in Idaho, Montana and Wyoming. According to Yellowstone biologist Doug Smith, the Yellowstone herds remain healthy despite its smaller size. The number is more in line with historic levels since wolves were reintroduced and grizzly bears and mountain lions returned naturally. Overall elk populations in the states of Idaho, Montana, and Wyoming remain healthy. However, elk populations are now more dynamic with the return of large carnivores and elk distribution has shifted to areas of refugia which make them more difficult to hunt.  Elk populations are affected by many variables including weather, disease, predation, and human mortality.

The Greater Yellowstone Coalition has consistently worked to find the middle ground on wolf management, to move beyond the ongoing conflicts. They continue to promote science-based management and increased tolerance for this iconic animal in the Greater Yellowstone Ecosystem.

How Wolves Change Rivers

Visit sustainableman.org/ to explore the world of sustainability.

For more from George Monbiot, visit monbiot.com/

"When we try to pick out anything by itself, we find it hitched to everything else in the Universe." - John Muir

When wolves were reintroduced to Yellowstone National Park in the United States after being absent nearly 70 years, the most remarkable "trophic cascade" occurred. What is a trophic cascade and how exactly do wolves change rivers? George Monbiot explains in this movie remix.

Wolves in Yellowstone prove one species' effect on ecosystem sustainability

 By Reno Berkeley

Sustainability. For conservationists, it’s one of the single most important issues facing our planet today. For others, it’s an inconvenient issue serving as a thorn in their side that prevents industrial and agricultural progress. The issue is very real, however, and even the smallest change in any given ecosystem can wreak havoc on the life that depends upon it.

Take the wolf, for example. While cattle ranchers and farmers don’t think anything of killing them for destroying their livestock (which is actually detrimental to our natural environment), the fact is, these animals are imperative for a healthy natural environment.Sustainable Man illustrates this point quite well in his video regarding how reintroducing wolves into Yellowstone National Park changed the ecosystem for the better. In 1995, the National Park Service reintroduced the gray wolf into the Lamar Valley of Yellowstone after the animals had largely been absent since about 1926. According to the NPS, the last wolf pack was killed in the park, but individual wolves were sometimes spotted.

Almost immediately, the small wolf packs began to make a difference. Prior to reintroduction, the deer population was out of control. Not even human efforts could curb the growth. As a result of this, vegetation began to decline due to overgrazing. After the wolf made its majestic reappearance in the park, the deer population fell, becoming more sustainable. The remaining herds learned to avoid certain places, like gorges, valleys, and anyplace they could easily be cornered.

Vegetation boomed, and because of this the rivers began to change. As George Monbiot explains in the video, the wolf’s presence had a positive domino effect: Because deer weren’t overgrazing and even avoiding places, all manner of vegetation made a comeback. Because the vegetation regenerated, the rivers through the park experienced less erosion. The rivers, which had previous Because of this rapid regrowth, birds and beavers returned. And beavers, as Monbiot states, helped create environments for other species, like otters and ducks. And the river became different. It slowed down in places, creating pools.

All this new life, all this new regeneration, because one predatory species was given a new chance in a place it had once called home for thousands of years. Because of federal government’s protection, the wolf population has grown to such an extent that they have been removed from the endangered species list. But the fight is not yet over.

Only the Mexican gray wolf remains federally protected, but even this species has its opponents. In New Mexico, one wolf is being removed from the wild due to a recent cattle-killing spree. Area ranchers aren’t happy and want the wolves gone. In California, the wolf may be removed from the protected list there.

In 2008, then-Alaskan governor Sarah Palin allowed the issuance of aerial hunting licenses so hunters could kill wolves. Her reason? To increase the caribou and moose population so humans could hunt and kill them for their dinner. It was not due to any real conservation efforts; it was for selfish purposes.

Obviously, wolves that prey on domesticated animals or those that hunt in areas humans frequent need to be controlled and removed. In the lower 48 states, the US Fish and Wildlife Service has suspended its plan to allow the killing of gray wolves pending further investigation. After learning more about how this species keeps its ecosystem in balance, I believe any plans to allow non-essential killing would be a bad idea.

Read more . . . 

Dispelling the Myths About Wolves

So why is the reintroduction of the gray wolf back in to areas that was once their normal range been such a divisive issue? Much of it has to do with myths, misinformation, unfounded fears and plain old misguided emotions. Throw in a substantial dose of political backscratching and couple that with state conservation agencies that are, in effect state game managers beholding to those who fund their existence - namely the hunting population. Now add to the mix a serious lack of understanding regarding the critical role that an apex predator plays in their relation to healthy ecosystem and you've developed a recipe for less than efficient wolf management.

Hunters, Politicians and Game Commissions

First, understand that I am not anti-hunting nor am I a preservationist. I am a conservationist - meaning I focus on the wise use of our natural resources. As some one who, by profession is engaged in wildlife management, it is important to know that I see sport hunting as a tool to support science based decisions. It should always be the means to an end . . . never as the end itself.

It is often said that hunters are the foremost champions of conservation. That may be true for some, but in my experience, it is not necessarily an accurate title to be bestowed upon the majority. The reasons that individuals hunt are as varied as they game the seek; however I dare say, conservation in the purest form would rank somewhere close to the bottom of the list. Admittedly, the dollars hunters pay in licensing fees, equipment purchase taxes, violation fines etc do go to support state conservation agencies. Unfortunately, today wildlife management in many states is not conservation as a scientific discipline. More often than not, state wildlife agencies are simply game managers - charged with ensuring that an adequate numbers of targets are available for the next season. Know that in no way do I mean to disparage the fine men and women who serve as game wardens, conservation officers, biologists and field technicians who dutifully serve to protect and manage wildlife. My issue is with the commissions that are owned by local, power hungry, vote thirsty politicians who dictate policy without the education or background to make the necessary decisions which would benefit the ecosystem. It is simply the corrupt tradition of "follow the money". 

Not the wolve's historic range?

I've heard and read many instances of people who have "verifiable proof" that many areas in US (including the Greater Yellowstone Ecosystem) was never the range for the gray wolf. This is pure fallacy. The historic range of the gray wolf covered nearly two-thirds of the United States.

The reintroduction of the gray wolf back into what was once their historic range was a monumental effort to right a terrible wrong - The decline of North American wolf populations coincided with increasing human populations and the expansion of agriculture. In the 1800's, westward expansion brought settlers and their livestock into direct contact with native predator and prey species. Much of the wolves' prey base was destroyed as agriculture flourished. With the prey base removed, wolves began to prey on domestic stock, which resulted in humans eliminating wolves from most of their historical range. Predator control, including poisoning, was practiced here in the late 1800s and early 1900s. Other predators such as bears, cougars, and coyotes were also killed to protect livestock and "more desirable" wildlife species, such as deer and elk.

By the start of the 20th century, wolves had almost disappeared from the eastern USA, excepting some areas of the Appalachians and the north western Great Lakes Region. The gray wolf's decline in the prairies began with the extermination of the American bison and other ungulates in the 1860s–70s. From 1900–1930, the gray wolf was virtually eliminated from the western USA and adjoining parts of Canada, due to intensive predator control programs aimed at eradicating the species. The gray wolf was exterminated by federal and state governments from all of the USA by 1960, except in Alaska and northern Minnesota. Thousands of wolves were killed from the early 1950s to the early 1960s, mostly due to poisoning.

Officially, 1926 was the year that the last wolves were killed within Yellowstone’s boundaries. When the wolves were eradicated and hunting eliminated, the elk population boomed. Over the succeeding decades, elk populations grew so large that they unbalanced the local ecosystem. The number of elk and other large prey animals increased to the point that they gathered in large herds along valley bottoms and meadows overgrazing new-growth vegetation. Because of overgrazing, deciduous woody plant species such as upland aspen and riparian cottonwood became seriously diminished. So, because the keystone predators, the wolves, had been removed from the Yellowstone-Idaho ecosystem, the ecosystem changed. This change affected other species as well. Coyotes filled in the niche left by wolves, but couldn't control the large ungulate populations. Booming coyote numbers, furthermore, also had a negative effect on other species, particularly the red fox, pronghorn, and domestic sheep. Ranchers, though, remained steadfastly opposed to reintroducing a species of animal that they considered to be analogous to a plague, citing the hardships that would ensue with the potential loss of stock caused by wolves.

In the 1960's and 70's national awareness of environmental issues and consequences led to the passage of many laws designed to correct the mistakes of the past and help prevent similar mistakes in the future. One such law was the Endangered Species Act, passed in 1973. 

The US Fish and Wildlife Service is required by this law to restore endangered species that have been eliminated, if possible. By 1978, all wolf subspecies were on the federal list of endangered species for the lower 48 states except Minnesota.

In 1991, Congress provided funds to the US Fish and Wildlife Service to prepare, in consultation with the National Park Service and the US Forest Service, an environmental impact statement (EIS) on restoration of wolves. In June 1994 the Secretary of the Interior signed the Record of Decision for the final EIS for reintroduction of gray wolves to Yellowstone National Park and central Idaho.

Staff from the National Park Service, the US Fish and Wildlife Service, and participating states prepared for wolf restoration to Yellowstone and central Idaho. The US Fish and Wildlife Service prepared special regulations outlining how wolves would be managed as an experimental population and Grey wolf packs were reintroduced to Yellowstone National Park and Idaho starting in 1995.

MYTH: Wolves cause significant losses to livestock producers * 

Averaged percentage of total sheep loss in Wyoming to various predators between 2000-2005. Wolves are responsible for less than 1% of losses

A common belief is that attacks on livestock by wolves is a significant, or even one of the primary causes that account for losses incurred by livestock producers.

In the US emphasis is placed primarily on the financial side, and also often emphasizes that the inclusion of the wolf within the Endangered Species Act violates "property rights" and "constitutional freedoms". The "emotional trauma" suffered by livestock producers as a result of predation is also frequently mentioned.

"It may destroy our livelihood, and our entire
lifestyle is also in jeopardy."

"A person doesn’t know or realize the emotional stress and fears of those that have had animals killed or maimed by wolves until you have it happen to yourself"

Though ranchers and farmers are always ready to give the numbers of livestock affected by predation, these are never given as percentages, or even stated in relation to total herd numbers. In most states the losses of livestock due to wolf predation was less than 1%. In the state of Wyoming, which lies entirely within the Yellowstone re-introduction area the number varied depending on year between 0.9% and 2% in the period 2000-2005, averaging under 1% over the period. This compares with 33.7% to 48.3% over the same period for losses due to coyotes, 4.1% to 10.9% due to eagles, and from 11.2% to 20.7% due to weather. Indeed, poison, often left by livestock producers to kill wolves and other predators, was often responsible for a greater proportion of losses than those due to wolf predation.

Emotional trauma is of course impossible to either prove or disprove, but it is important to remember that livestock is ultimately reared for slaughter, either to directly obtain the primary products (meat and hides) or as means of profitably disposing of "spent" dairy or wool herds/flocks. Thus one would expect anyone working in the livestock industry to deal with the death and processing of animals into food and other end-products as part of the day to day running of their business. It is highly unlikely that any individual emotionally disturbed by the slaughter of animals for meat or other products would find livestock work tolerable as a long time career.

The inclusion of wolves in the ESA provides a mechanism for financial compensation to be paid for damages caused by wolves in partnership with the Wolf Compensation Trust, and in the case of wolves found in the act of attacking livestock or other domesticated animals within private property, it is permissible for the owner to take measures necessary to protect them. Therefore it is hard to see how such an act can be a "violation" of rights.

Adult wolves kill each other in territory disputes. Such disputes happen each year, but increase when food is less abundant. This may have been why so many adult wolves died in fights during 2008. That year, scientists also found two wolves whose deaths were partially due to starvation.

MYTH: Wolves decimate game herds

"All wolves must be eliminated to restore our big game herds."

"The Canadian wolves have decimated our elk, mule deer and moose populations to lows not seen since the ’60s."

There has been considerable misinformation over the impact of wolf populations on herds of elk. However the National Park Service studies indicate that wolf reintroduction to the park, a major reserve for elk herds, would have negligible affect on hunting activities, and that the effect of wolf predation on elk populations would not, in and of itself, have an impact sufficient to be the decisive factor in elk population management.

Although the reasons behind fluctuating wild animal populations are complex, Drs. Doug Smith, Daniel Stahler and John Vucetich conducted a joint National Park Service-MTU study into elk population at Yellowstone. Their findings found that:

• Elk population remained stable from the re-introduction of wolves in 1995 through to 2000, at around 17,000
• In the period 2000-2004 the population dropped 50% to 8,334. During this period the Greater Yellowstone Ecosystem area experienced drought conditions, and increased hunting of Elk by humans.

Though hunting permits did not allow for a kill level equivalent to the total population drop, the researchers concluded that hunting, led to a "super-additive" effect, whereby a 1% direct loss rate due to hunting was magnified to significant degree due to knock-on effects, which were only exacerbated by drought conditions. A recent study conducted by Montana Fish, Wildlife and Parks found that the primary killer of elk were mountain lions, followed by bears and wolves came in a distant third. Although wolf predation was acknowledged to exist, it's effect on the large population drops seen was regarded as a minor, largely insignificant factor:

"Our analysis indicates that there is greater justification for believing that the harvest rate and severe climate, together, account for at least much of the decline".

MYTH: Wolves attack humans all the time

While it is known that wolf attacks on humans do occur, those engaged in wolf hysteria deliberately exaggerate the risk out of all proportion to implant the idea in their audience that all wolves routinely kill and eat humans.

"Wolves are blood-thirsty predators that attack and kill pets, livestock, children, and adults"

"...we need to protect [the cattle industry] from these intruders...they’ve moved into my ecosystem, not the other way around"

"258 Congressional Members Support Funding for Mexican Wolves Stalking Children and Wolves Terrorizing Rural Citizens" The facts in no way bear out such hysteria. Those involved in wolf misinformation often recount reports from the 18th and 19th centuries recanting real or imagined wolf attacks in Europe and Asia.  Although European wolf subspecies are less wary of humans, and are able to live near higher-density human populations than their North American cousins there are no reports of attacks. As the map clearly shows, no wolf subspecies present on the Eurasian landmass is present on the North American landmass. Statistics compiled by Norwegian Institute for Nature Research (NINA) on global wild (not captive) wolf attacks show that in the period 1950-2000, (50 years) there were only 13 confirmed cases of wolf attacks on humans in North America, none of which were fatal. In the United States alone, approximately 1 million reported instances of domestic dogs biting humans per year, with an average of 16 to 18 fatal attacks per year. MYTH: Wolves spread disease Groups and politicians opposed to wolf conservation often use the claim that wolves spread diseases to livestock and game populations. Whilst wolf populations, like that of any wild animal, carry disease, as apex predators they are more often than not a "dead end" for transmission of disease, and are of little concern when it comes to disease management in most livestock and game populations. The most serious diseases affecting wolf populations are those which also affect domestic canines: parvo, mange and intestinal worms. In all cases, transmission of the disease is driven infinitely more by domestic dogs than wolves, and it is believed that in most cases these diseases have been introduced to the wolf population by domestic dogs. A notable exception is the presence of mange in North American wolf populations in the Rocky Mountains. This population was deliberately infected by government veterinarians in 1909 as an attempt to "exterminate" the wolf population, spread to coyotes and other mammals, and eventually re-infected wolves upon their reintroduction to the area. MYTH: Killing/trapping/hunting is the solution "I believe wolves need to be eliminated" A common refrain is that the only effective solution to any or all of the above is to drastically reduce the population of wolves. This inevitably entails lethal intervention on the part of humans. Such actions are proposed by many livestock producers as the panacea to all ills, and is, unsurprisingly, encouraged and guided by the hunting, trapping and fur lobby organizations, which naturally present themselves as the only viable way of going about any such lethal solution. Unfortunately, many hunting methods are exceedingly inhumane, with methods such as leg traps being commonplace in North America, though are banned in the EU due to concerns over its inhumane nature. * From "Wolf Hysteria"