Protect The Mexican Gray Wolf
  • Petitioned President of the United States

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U.S. Senate
U.S. House of Representatives

Protect The Mexican Gray Wolf

    1. Ruth McD
    2. Petition by

      Ruth McD

      Redmond, OR

Amendment No. 342: None of the funds made available by this Act may be used for the continued operation of the Mexican Wolf recovery program.

Despite the fact that 69% of New Mexicans support the reintroduction of Mexican wolves after five decades of extinction in the wild, Mexican wolves remain in peril of a second extermination from the Southwest. 

At only 50 lobos in the wild, the Mexican gray wolf is the most endangered wolf and mammalian species in North America. However, this hasn%u2019t stopped an onslaught on them and their also-imperiled Northern cousins from both houses of Congress. Two mirror bills (S.249 & H.R.509) are now advancing through the Senate and House with the same intent: to remove Endangered Species Act protections from all gray wolves in the United States. 

What will happen if federal protections and funds are removed from wolf management in New Mexico? All new wolf releases will cease and management of lobos will revert to state wildlife authorities, who, unlike federal biologists, are not bound by %u201Cbest available science%u201D requirements. Simply put, this will spell doom for the vital reintroduction of wolves in Southwest. 

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    • Camryn Lee BRUSH PRAIRIE, WA
      • 9 months ago

      I have reviewed the Proposed Rule to Remove the Gray Wolf (Canis lupus) from the List of Endangered and Threatened Species and Maintain Protections for the Mexican Wolf (Canis lupus baileyi) by Listing it as Endangered and find that the proposed delisting of the gray wolf (wolf) is not supported by logic, relevant facts, rational thought, or reason or best available science, and it contains numerous inconsistencies and contradictions. Therefore, I do not agree that the wolf no longer warrants protections provided by the Endangered Species Act (Act).

      As a retired U.S. Forest Service and U.S. Fish and Wildlife Service Wildlife Biologist who specialized in rare carnivores, I feel well-qualified to provide the following response, information, general, detailed, and specific comments regarding the Proposed Rule, as well as the potential implications of the Proposed Rule if it were to eventually become the Final Rule issued by the Service. My comments regarding the Proposed Rule, appear below.

      The Proposed Rule is inconsistent with the primary principles and mandate of the Act, I.e. ‘to conserve, enhance, and protect endangered and threatened species and the ecosystems upon which they depend’. The US Supreme Court’s first interpretation of the Endangered Species Act [ESA] (TVA v. Hill, 1978) found that "the plain intent of Congress in enacting" the Act "was to halt and reverse the trend toward species extinction, whatever the cost."

      The implementing regulations, policy, guidance and actions of the Act are to: ensure that decisions under the Act represent the best scientific and commercial data available [59 FR 34271]; incorporate independent peer review into listing and recovery activities [59 FR 34270]; solicit participation of States, Tribal, and Federal agencies, academic institutions, private individuals, and economic interests in recovery efforts [59 FR 34272]; and incorporate an ecosystem approach into ESA activities [59 FR 34275].

      In the Proposed Rule, the Service states that after a thorough evaluation of the best available scientific information they determined that Canis lupus and Canis lupus subspecies in the contiguous United States do not warrant listing under the Act. The Service claims that recovery efforts in the NRM and Western Great Lakes regions have been successful.

      Attempts to Revise the Definition of Endangered & Significant Portion of Range

      Prior to this Proposed Rule, it was well-recognized that wolves were still in grave danger of extinction throughout a significant portion of their historic range. That is why the species is currently listed as Endangered under the Act. However, in a series of attempts to dilute the protections provided by the Act, especially with respect to wide-ranging, highly controversial species, such as the gray wolf and grizzly bear, the Service and NOAA Fisheries Service (Services) jointly proposed a policy to allegedly “improve and clarify” implementation of the Act by providing a formal interpretation of the phrase "significant portion of its range" as it appears in the ESA.

      The proposed policy is both misleading and deceptive as it would not improve ESA implementation. Despite these failings and abridgment of law, It would, however, provide a consistent and uniform standard that the Services could then use to delist whatever species it deems no longer in need of federal protection. The proposed re-definition misrepresents facts that have become so controversial that pervasive uncertainty about the meaning of this important phrase has prompted several years of debate and litigation. A formal opinion developed by the Solicitor of the Department of the Interior has been applied by the Service since March 16, 2007, ignoring the fact that the formal opinion was withdrawn on May 4, 2011, after two courts rejected key aspects of it. Meanwhile, NOAA Fisheries never applied the Service’s interpretation, nor did it attempt to issue separate guidance.

      Therefore, the ultimate definition of the phrase "significant portion of its range" (SPR) and “Endangered” (E) as these appear in the ESA are extremely important concepts with respect to wolves. United States Senator Tumney explained that a species might be considered Endangered or Threatened and require protection in most States even though it may securely inhabit others (Defenders of Wildlife v. Norton, 258 F.3d 1136, 1144-45 (9th Circuit 2001). Until recently, the Service interpreted the SPR-phrase to include both a species’ current and historic range for listing purposes, and had objected to attempts to narrow the definition (Enzier and Bruskotter 2009). However in recent years, the Service has asserted that the “range” in the SPR-phrase refers only to the range in which the species currently exists. This interpretation has been criticized in the scholarly literature (Carroll et al. 2010) and generally rejected by the federal courts for failure to adequately protect T and E species (Enzier and Bruskotter 2009).

      Interpreting the range of the species to mean the “current range” is functionally identical to striking the SPR-phrase from the Act entirely and redefining Endangered, thereby narrowing the definition of Endangerment to that which was explicitly rejected by Congress when the ESA was originally enacted. In most cases, species are listed as Endangered because current range has been reduced by human actions and the Act is intended to mitigate such reductions in range, not merely to describe them.

      The Proposed Rule would delist the species and thereby remove all protections of the Act. As expressed by Kevin Hartnett (2013), although one might think simple arithmetic would be sufficient to decide which animals require a place on the Endangered Species List, the ongoing controversy around the status of wolves illustrates that defining a species as ‘Endangered’ is not straight forward.

      Despite decades of federal protection and re­introduction programs, the Service found that the Western Great Lakes (WGL) and the Northern Rocky Mountain (NRM) wolf populations recovered sufficiently to warrant removing ESA protection. Wolves in both areas were ‘delisted’ by August 2012 (Woolston 2013). Now that the WGL and the NRM populations are ‘out of the way’, the Service proposes to remove protection from ALL wolves, using earlier reviews as evidence of wolf recovery and arguing that the original wolf listing erroneously included regions outside of the species’ historic range. The Service further implies that by delisting the remaining contiguous US wolf population, it can concentrate resources on protecting the Mexican wolf (Canis lupus baileyi) (Woolston 2013).

      Thus, this Proposed Rule marks a critical turning point for wolves. Now, six states have wolf-hunting seasons and if the species is delisted, wolves will be managed by each individual State. Unfortunately, most States do not show an interest in wolf protection or enabling wolves to re-establish into much of their historic range. As such, delisting the wolf could essentially prevent wolves from ever reclaiming the majority of their historic range, except within the NRM and WGL regions.

      IS THE SERVICE USING THE BEST AVAILABLE SCIENTIFIC INFORMATION?

      In an article entitled ‘Hunting Wolves In Montana - Where Are The Data?” that appears in Nature and Science (2011), the author (Jay S. Mallonee) found that management agencies claim that recovery and public hunting of wolves is based in science. A review of their statistics demonstrates that data collection methods used by the Service did not follow a scientific protocol which thereby resulted in flawed and often incorrect data. Consequently, agencies do not know and could not possibly evaluate, assess or determine the total number of wolves in Montana, which is a major reference point used by State and Federal wolf managers. Therefore, the quotas proposed for public wolf hunts are completely and entirely arbitrary. Thus, management decisions made by the Service, the State, livestock owners and hunters are not been based on facts. This has produced a wolf management system that lacks any scientific perspective and does not utse what is well-known about the wolves’ role in sustaining a healthy ecosystem. Instead, the absence of verifiable data suggests that management decisions are being based solely on the opinion of a select audience and certain politicians rather than true science and the mandate to use the best scientific information available. As such, and because the wolf hunting season has such a short history in Montana state, it is extremely premature, unreasonable, and frivolous to consider the Proposed Delisting of wolves without any actual data to confirm that this is a reasonable and prudent measure being taken by the Service in behalf of the species which it is mandated to protect.

      WOLVES ARE PART OF A HEALTHY FUNCTIONING ECOLOGICAL SYSTEM

      Ecosystems are an intricate myriad of relationships and interactions based on the need of every living organism to gain nourishment, survive and reproduce. These complex tangles of interactions act as food webs (O’Gorman et. al. 2009). Predators, such as wolves, are an integral part of a healthy functioning ecological system.

      Predators impact their environments because they survive by preying on other organisms, thus they send a ripples effect throughout the food web, which in turn regulates the effects that other animals have on that ecosystem. This trophic cascade of cause and effect has direct and indirect impacts across all lower levels of a food chain (Beschta 2009).

      An example of trophic cascades occurs when wolves prey on ungulates (elk, deer, moose), which keeps the ungulates moving and reduces their population densities. This limits the impact that ungulates have on plant biomass so that more vegetation can grow. This, in turn preserves and/or creates habitat for many other species, ranging from insects and reptiles to otters and songbirds, especially near riparian areas. This simultaneously helps prevent soil erosion, which has another set of positive consequences on water quality and other hydrologic aspects. The value, importance and critical influence of predator-prey impacts and relationships cannot possibly be overstated. The entire composition of plant species in any naturally occuring area is an extremely important regulating factor of any healthy ecosystem function (Schmitz 2009). These impacts occur in every terrestrial and marine ecosystem on earth.

      In addition, predators such as wolves, have other impacts throughout their communities because they affect the behavior of competitive predators, such as coyotes or bears that eat some of the same prey they do. Dominant predators, like wolves, will even kill and eat their competitors (Berger et. al. 2007). This, in turn, impacts every animal in the competitor’s food chain. One of the most frequently studied dynamics between predators involves wolves and coyotes. Wolves regulate the numbers, movement, and distribution of coyote populations because wolves are the dominant species over coyotes. When coyote populations are held in check, every animal that is further down the coyote’s food chain (such as birds and rodents)tend to have higher survival rates, as has been found with pronghorn antelope (Berger et. al. 2008) and sage grouse (Mezquida et. al. 2006). Thus, wolves help support all of the prey species at lower levels, which triggers an array of other effects which contribute to the healthy functioning of a natural occuring ecosytem.

      In a decisive study on the effects of predators on the environment, Ripple and Beschta (2006) of Oregon State University, found that the presence of large predators is important in sustaining native plant communities in both upland and riparian areas because plants contribute to a wide range of ecosystem services such as floodplain functioning, soil development, and stream bank and channel stability. Riparian areas are biodiversity “hotspots” because the diversity of native plants commonly present in riparian areas actually provides habitat and food that supports a large number of terrestrial and aquatic species, ranging from amphibians and birds to fish and insects (Beschta and Ripple 2009). By contrast, “in areas where livestock foraging is the dominant land use, simplification of plant communities, reduced ecosystem services, impacts to wildlife, and a shift towards alternative states are common” (Beschta and Ripple 2009).

      Predators are important to the health of a diverse, functioning ecosystem not only because they create biodiversity, but also because they indicate that biodiversity actually exists (Sergio et. al 2008). Predators such as wolves regulate natural systems as described above, but they also (especially top predators such as wolves) serve to measure the true health of the natural communities of flora and fauna that surround them. Pinnacle predators, like wolves, are associated with high biodiversity value because (Sergio et. al. 2008) they are sensitive to ecosystem dysfunctions, such as pollution, habitat fragmentation, and other human impacts that would affect many other species. Predators, such as wolves, select sites with productive habitat and vegetational complexity; most have diets that are dominated by a few main prey species and a large number of secondary prey species. Those communities with many prey species are richer and allow for prey-switching if necessary, which in turn helps prey populations persist while still allowing for top-down regulation of the area by the predators/wolves. Studies show that carnivore density is correlated with ecosystem productivity and services including the health of soil, water, and vegetation. Pinnacle predators, such as wolves, typically need large areas for foraging and breeding. Thus, they are considered umbrella species; I.e. if an area supports a large predator then it will encompass the requirements of all lesser demanding species beneath them in the food chain (Sergio et. al 2008). Because of their large home range size requirements, it is well-recognized that predators, such as grizzly bears and wolves, are an enormous draw for tourists, which SHOULD encourage the Service to provide for the protection of the species and the ecosystems upon which they depend (as mandated by the Act) while generating a significant amount of income throughout rural communities across the US and increased employment opportunities that previously did not exist, such as outfitters and guides whol lead winter ski trips into the Greater Yellowstone Ecosystem (Berger 2006).

      The majority of Americans are intelligent enough to recognize that all ecological processes mentioned above are part of the larger natural world, which operates based upon intricate fundamental laws that cannot be replicated by human beings. These processes took thousands of years to evolve and they affect not only plants and animals, but our own survival as well. Not only do wolves contribute to important tangible benefits to human health, such as improved water quality, but they also contribute intangible aspects of our such as our quality of life, our spiritual, cultural, ethical, and moral well-being. Preserving large predator species as a part of an intact natural ecosystem is a profound act of wisdom, integrity, and self-preservation.

      THE ECONOMIC BENEFITS OF WOLF CONSERVATION

      During 2006, 31% of the U.S. population (16 years old and older), participated in wildlife-watching activities. People who took an interest in wildlife around their homes numbered 68 million, while those who took trips away from their homes to watch wildlife numbered 23 million people (USFWS 2006). A primary finding indicates that nature-related tourism and recreation are one of the fastest growing trends nationally, regionally, and particularly within the Pacific Northwest and GRM region. In Montana, where wolves persist, a higher percentage of residents participate in nature-related recreational activities; in particular, hunting, fishing, and wildlife viewing, compared to other states. Non-resident travel is also closely linked to wildlife and fish resources. Wildlife viewing is one of the top two reasons people decide that their travel destination should be Montana state. Expenditures for travel/tourism in the State are greatest around Glacier National Park and YNP, but throughout the west and central Rocky Mountain front, non-resident expenditures are very significant. The fact that 9.8 million visitors come to Montana represents ten times Montana’s resident population and results in 43,300 jobs resulting in an economic impact of $2.75 billion dollars. While participation in wildlife viewing in rapidly increasing nationally, hunting is declining nationally. In the GRM region, the percentage of the population participating in hunting is larger than the nation as a whole (8% nationally, 12% in the Rocky Mountain West and 33% in Montana state).

      Although potential participation in wolf viewing is unknown, respondents to a random survey in Idaho indicate that 42 percent of non-hunters would travel long distances simply to potentially see a wolf and 20 percent of non-hunters would pay an average of $123 to an outfitter/guide to potentially see a wolf (Idaho Department of Fish and Game (IDFG) 2008). In the same survey, 20 percent of hunters said they would travel to see a wolf and on average hunters would pay less than people who are interested in ‘Watchable Wildlife ‘opportunities as hunters say they would only pay $115 to an outfitter/guide for the opportunity to see a wolf (median = $100). Obviously, it is of greater economic value to the state of Montana to ensure Watchable Wildlife opportunities increase, IF the State is truly interested in providing jobs, new sources of income - both to individuals, businesses, and the State coffers.

      Wildlife viewing areas are popular among the public and viewing Watchable Wildlife is a an enormously growing pastime among Americans (USFWS 2006). Viewing big game animals such as deer, elk, mountain goats and bighorn sheep is common and especially popular when they are easily viewed from roads or designated Watchable Wildlife viewing areas (now commonly used US Forest Service terminology). Large ungulate viewing occurs despite annual hunting seasons. Similarly viewing opportunities could be made available for wolves throughout the all states where they occur, despite annual hunting. However, as is the case with other large predators, viewing opportunities will be naturally seasonal because these species occur at relatively lower densities, and due to hunting pressure they have become much more secretive, afraid of humans, and they are highly mobile. Developing Watchable Wildlife viewing areas would only require federal agencies to cooperate with citizens, landholders, and other interested or affected parties who might benefit from or fear such economic tourism improvements and opportunities.

      WHAT IS ‘RECOVERED’; ‘A SIGNIFICANT PART OF ITS RANGE, AND ‘ENDANGERED’

      Based on simple calculations, the NRM and WGL regions represents roughly 15 percent of the historic range of gray wolves in the contiguous US. The Proposed Rule indicates that the Service considers the wolf to be ‘recovered‘ through a "significant portion of its range", despite the fact that wolves are essentially extinct in the remaining 85 percent of their historic range. The Proposed delisting of wolves would essentially prevent them from ever reclaiming large portions of their historic range in places such as California, the southern Rockies, and the Northeast. The Proposed Rule would remove all wolves from ESA protections throughout the entire conterminous US. The future of the species depends on a definition of ‘Endangered’ that is inconsistent with the legislative history and historic implementation of the Act, as well as numerous court rulings.

      The Proposed Rule also asserts that areas where wolves once existed are “unsuitable habitat” because human inhabitants of these areas lack any tolerance for wolves. That claim entirely ignores a significant body of scientific knowledge suggesting otherwise. By effectively narrowing the definitions of ‘Endangered”, as well as “significant portion of its range’, and ignoring the best available science regarding tolerance for wolves, the Proposed Rule would set an extremely unfortunate precedent with far-reaching consequences, including dramatically limiting recovery efforts for many other species currently protected by the ESA (Bruskotter, et. al. 2013). It is apparent that the actual intent of the Service is to make it easy to justify removing Endangered status of wolves everywhere in the US.

      As the appearance of the wolf in Kentucky suggests, wolves are known to push boundaries. In the spring of 2013, a gray wolf was shot to death in Kentucky, a State where wolves had been extirpated since the 1800’s. Because this was the first free-ranging wolf in the State’s history, no Federal or State charges are expected. The Kentucky Department of Fish and Wildlife Resources released a statement on August 14, 2013 that a Hart County resident shot the wolf at 100 yards while hunting coyotes. Officials from the US Department of Agriculture National Wildlife Research Center in Colorado performed a DNA test that conclusively proved that it was a gray wolf (Romans 2013). This was the first wolf shot in Kentucky in more than 150 years; just one example of why federal policy-makers are keen to re-examine and redefine portions of the Act and the definitions therein.

      Potential Impact of Delisting Wolves on States Adjacent to the NRM Population

      The Service would argue that because the species is essentially recovered in the NRM region, for example, then adjacent States, such as Washington and Oregon, would manage the species according to their respective Management Plans. The problem with this concept, however, is that these plans only provide management guidelines and they are not enforceable as laws that would protect wild wolves from being shot, trapped, poisoned, maimed and/or killed. In actuality, the Service’s proposed delisting of wolves is simply a continuation of the agency’s long retreat in the face of wolf hating intimidation (Gibson 2013). Some wolf advocates hope the taxonomic shell game will be so crude and obvious that public outcry over the wolf delisting will persuade the Obama administration to withdraw the proposal (Gibson 2013). Noah Greenwald from the Center of Biological Diversity argues that “The majority of Americans support protection of Endangered species and they support protection for wolves. I would like to think the Obama administration is not tone deaf.” (Gibson 2013).

      “If history repeats itself, and the unexpected always happens, how incapable must man be of learning from experience.”

      As quoted from George Bernard Shaw

      If history is any indication of what will happen in the future, we need only look at Montana (MT) as a shining example of an inconceivabley deep-rooted hatred of wolves, inspired primarily by a loose coalition of ranchers and ruthless hunters‘ groups who want to kill wolves simply for the sake of killing, rooted in a narrow minded self indulgent culture of fear and loathing as well as ignorance of the important ecological role and value of the wolf on the landscape. In Montana, the wolf is no longer afforded the protections of the Act and is thus at the mercy of the State in terms of its’ management. The following information regarding the management of wolves in MT is intended to help outline precisely what will most likely happen in States adjacent to MT, such as Washington. The State has shown a dismally sincere lack of commitment to revise anything related to ethical wolf management, undermining the potential for wolf survival and recovery into the future. MT has exhibited incessentincessant efforts to remove protections still afforded by the MT Wolf Management Plan.

      In summary, MT is in process of Administrative Rule modifications regarding wolves, spurred by wolf management or mismanagement bills passed by the last legislative session. House Bill (HB) 27 attempted to authorize the use of silencers while hunting wolves – indicative of the political climate and culture, this passed in both the House and the Senate, only to be vetoed by the Governor; HB 31 allowed hunters to use recorded or electronically amplified sounds (e.g. the sound of wounded prey or the howl of another wolf) in order to attract wolves to prospective hunters - this ‘fair’ play concept was incorporated into SB 73 which also revised wolf hunting laws so that MT Department of Fish, Wildlife and Parks (MFWP) can NOT prohibit wolf hunting in ANY area immediately adjacent to Glacier National Park, Yellowstone National Park, and all other National Parks in the state of MT so that, in essence, hunting and trapping are always open in those areas unless a wolf harvest quota (established for that area) has been met. Never mind that a hunter can draw in wolves with recorded devices so that wolves in the National Parks might meet their fate within yards of a National Park, MT also lacks an accountable monitoring plan that would enable FWP to determine if a quota has been met. Furthermore, there is insufficient funding to determine when or if a quotas was ever met in the first place, so there will be no way to establish the actual status of wolves in MT. SB 73 further removes the requirement that hunters wear orange vests outside of the ungulate hunting season (which barely overlaps the wolf hunting season), so be sure not to visit any National Forests in MT during wolf hunting season...in case you, you’re dog, or your children be mistaken for a wolf. To make matters worse, SB 73 reduced the price of a non-resident license fee from $350 to $50, ensuring that there will be more hunters streaming into MT to enjoy their share of the killing spree, while denying the State needed funds to responsibly manage its wildlife. This reduction in the cost of a wolf hunting license is especially egregious in light of the fact that non-residents are willing to pay more money simply for the chance to see a wolf versus the amount of money a non-resident pays in order to kill one.

      As time progresses, MT continues its’ march toward the emancipation of hunters and ranchers from the presence of wolves. HB 150 proposed that wolf licenses should be free with the purchase of a big game license, but of course that would mean that killing wolves would not provide money to fund jobs for MFWP employees, so HB 150 was tabled. The most heinous of all the Bills thus far is Senate Bill (SB) 200, which revised laws related to wolf management. SB 200 authorizes landowners or their agents to kill wolves on their property without any license or administrative oversight simply based on their perception of a potential threat, I.e. if they perceive that a wolf might ever consider preying on their livestock, they can kill any wolf they see. This eliminates prior requirements that a wolf was actually in the act of killing/attacking livestock. Now a wolf merely has to cross private land and it is fair game to shoot it on sight - based on suspicion of malicious intent. As if the litany of laws that enable wolf hunters and trappers is not enough, Montana Fish Wildlife and Parks 2013-2014 Wolf Hunt Proposal now permits each hunter to bag up to five wolves (potentially an entire pack). These actions simultaneously and cumulatively move Montana away from it’s Citizen Stakeholder Management Plan, so that those citizens who actually value wolves, or who may benefit economically through wildlife watching and tourism industry, or who want wolves to remain as members of the natural ecosystem and/or value them as part of their natural heritage, these people are being pushed out of consideration.

      In case anyone was concerned that wolves still had too much of a chance at surviving in the GRM, HB 33, which fortunately died in committee, would have mandated the killing of wolves if they ever attack any livestock or chickens or beehives and this applied despite the fact that a landowner might intentionally have left their chickens out simply so that they can kill every wolf that comes in to take advantage of their carelessness. Of course, there is absolutely no requirement that a landowner exhibit any accountability or responsible behavior in terms of maintaining fences, keeping their chickens inside at night, using livestock guard dogs, or any other non-lethal preventive measures that a responsible livestock owner would normally do. Even if wolves did not exist, there are thousands of coyotes and in actuality they outnumber wolves by more than 10,000:1.

      In case all this was not archaic enough, the Montana legislature passed HB 27 permitting sound reduction devices for wolf hunting and after it was vetoed by the Governor, it introduced HB205 to allow hunters to use silencers on their guns, so that not only wolves, but also big game and people living, recreating or even hunting in the area would have no warning that a or another hunter was in the area. Is this what MT considers fair play? Lastly, the coups de gras is SB 397, would have permitted ranchers, hunters and trappers to kill wolves, bears, and mountain lions nearly year-around. In other words, it’s open season on predators 10 months of the year. SB 397 also would have allowed bear-baiting, using hounds to hunt bears, and the use of snares to trap wolves. Snares are wire loops that choke an animal to death and any wildlife or domestic dog that gets caught inside one will hideously suffer a painful death. SB 397 Passed in the Senate, and made it well through the Montana House, before after four months and 38 actions, finally died in committee. Perhaps there is one sensible politician in Montana, but not much more. As these political actions demonstrate, if it was up to Montana legislators and his or her constituents, irrationality would prevail and every wolf in the state would be once again threatened, if not endangered, or extinct.

      While on the subject of killing wolves, it is appropriate to mention that your tax dollars pay for both the cost of killing wolves and the cost of maintaining range allotments on our public lands. These range allotments are on public lands and they only benefit farmers and ranchers, citizens who make up 5 percent of the total population in Montana. In fact they benefit only the ‘government ranchers’, those fortunate enough to allotments on public lands, where low grazing fees give them a grossly disproportionate economic advantage over their neighbors. The Montana Livestock Loss Board claims that livestock producers absorb most of the financial impacts of wolf recovery through uncompensated predation losses, reduced productivity related to stress on their livestock, and increased personnel costs associated with livestock protection and management (MFWP 2008). Financial compensation in MT comes in the form of reimbursements by the MT Livestock Loss Board (MLLB) which was created by the 2007 MT Legislature to fulfill the compensation provisions of the 2003 Gray Wolf Plan. The program is based on the belief that both government and livestock producers want to take reasonable and cost-effective measures to reduce losses, that livestock owners should not incur disproportionate impacts as a result of recovery of Montana’s wolf population. It also acknowledges that it is impossible to prevent all losses from occurring.

      According to the USDA Cattle Death Loss Report (released May 12, 2011 by the National Agricultural Statistics Service), cattle loss in Montana that is due to predators represents only 6 percent of all causes of cattle deaths from ALL causes. Coyotes and dogs cause the majority of cattle losses, accounting for 53 percent and 10 percent of losses, respectively. The remaining losses are due to (in this order) cougars, bobcats, lynx, vultures, wolves, black/grizzly bears, and other undetermined predators.

      The USDA does not examine livestock animals that were killed in order to determine if they were actually sick/ill/diseased/injured prior to being killed. While it is now well-recognized that medical/bio-detection dogs are used to detect diabetes, clostridium difficile (the cause of many hospital acquired infections) ovarian cancer, bladder cancer, lung cancer and many other diseases with up to a 92 percent success rate there is no corresponding information with respect to wolves and other predators. However, it is very likely that wolves, who depend entirely on finding weak, sick, ill, diseased, old, young, and injured prey, would be even more capable of detecting diseased prey/livestock than dogs are capable of doing with humans. It would be extremely interesting if these data were collected on all documented wolf kills to determine if the prey (when it is livestock) was actually ill/diseased.

      According to a Wildlife Services Fact Sheet (2010), coyotes are also the leading cause of all sheep and goat predation, as well. As noted in Yellowstone National Park, if wolves were ever truly allowed to recover, coyote populations would decline and the entire ecosystem would be much healtheir, particularly riparian areas and water quality. The simplest non-lethal predator control measures are the use of guard animals, exclusion fencing and flagging, herding, night penning, fright tactics, livestock carcass removal (obviously leaving dead livestock out will attract predators), and culling out sick animals, but in Montana, only 3 percent of ranchers used exclusion fencing that would enable predators to discern human property boundaries and only four percent of livestock owners used fright tactics. The most common method used by only 37 percent of ranchers was to remove livestock carcasses. Apparently, the vast majority of ranchers prefer to use lethal measures against potential predators and depite data to the contrary, they blame wolves for livestock losses rather than hold themselves accountable for maintaining their own herds/property and choosing to use non-lethal predator control measures.

      It should not come as a surprise that the USDA Cattle Death Loss Report (2011) found that in Montana, 94 percent of all the total losses of livestock were related to the farmer/rancher/livestock owners’ own lack of proper veterinary care, failure to vaccinate/innoculate animals, inadequate maintenance of fencing, failure to frequently check on livestock, etc. These causes include digestive, respiratory, metabolic, and weather related problems as well as mastitis, lameness, injury, calving problems, poisoning, theft, and other non-predator related causes. Yet, the myth of wolves being the primary cause of all woes continues and is perpetuated by the hysteria that is flourishing in MT.

      The Economic Benefit of Wolves

      Each year, people come to Yellowstone National Park (YNP) hoping simply to catch a glimpse of a wolf and they spend about $35 million in MT, Idaho and Wyoming. This is money that would not have otherwise been spent there (Stark 2006). According to an intensive study of YNP visitors conducted by University of Montana economist, Dr. John Duffield and his colleagues, the potential of seeing a wolf has an enormously positive impact, estimated at $70 million dollars. This amount of money far offsets losses to livestock owners and hunters. Duffield presented his findings in Missoula, MT during the 18th Annual North American Wolf Conference. He surveyed about 1,900 visitors to YNP between December 2004 and February 2006. Visitors were asked why they came to YNP, what they hoped to see, their opinions about wolves and their spending habits. The economic impact figures are based on those who said they would not come to YNP if wolves were not present. Duffield's research found that wildlife viewing is the main attraction for YNP visitors and that the animals they want to see the most, are, in order, grizzly bears, wolves, mountain lions, moose and black bears. Duffield, estimated that roughly 151,000 people see wolves each year, including about 27,000 visitors each winter. About 70 percent of people who live in the greater Yellowstone area approve of the wolves' presence. Some people worry that attitudes toward wolves are shaped by inaccurate information (Stark 2006).

      Montana serves as a good test case. With delisting, the worst in social attitudes was unleashed. The Service should do the job they ARe paid to do. Monitor what is occurring in the NRM wolf population before unleashing this same social and political vitriolic, ferocious and monstrous mentality across the country.

      GAO REPORT ON FEDERAL EXPENDITURES TO BENEFIT LIVESTOCK GRAZING

      In an amazingly honest, open and persuasive report, written by the US Government Accountability Office in a Report to Congress, dated September 2005, it is well-documented that federal expenditures clearly benefit ranchers who have range allotments on public lands; that these ranchers are subsidized by the federal government at a significant cost to taxpayers, while the federal government simultanesouly spends millions of dollars each year to eliminate predators on federal lands owned by all Americans, not just ranchers.

      The GAO Report (2005) found that unreasonably low grazing fees subsidize ranchers at a very high cost to tax payers. Americans might wonder why the government chooses to subsidize livestock ranchers rather than, perhaps choosing to subsidize health care workers, teachers, nurses, or war veterans, for example.

      The ecological costs of livestock grazing exceeds that of any other Western land use. Livestock grazing destroys vegetation, damages wildlife habitat, disrupts natural processes, wreaks havoc on riparian areas, rivers, grasslands and forests thereby causing significant harm to ungulates and the ecosystems on which all species, including humans, depend. Despite these costs, livestock grazing continues on both State and Federal lands throughoutthe West. Livestock grazing is subsidized, promoted, and protected by the US Forest Service and the Bureau of Land Management (BLM) on billions of acres of public land in the Western US. Federal-land livestock grazing enjoys a $100 million dollar direct annual subsidy. Indirect subsidies may be three times that amount. On the Tonto National Forest in Arizona (in 2004 and 2005), ranchers were subsidized under just one federal program to the tune of $3.5 million dollars for their “range improvements.” Grazing is even permitted in our National Parks, which are not intended to encourage livestock production at the cost of the naturally occuring species that would exist there, such as bison, wolves, grizzly bears, Canada lynx and wolverine.

      One study examined the reliance of ranchers on federal land in eleven western states and showed that only $1 of every $2,500 of income (0.04 percent) earned in those states is directly associated with grazing on our publicly owned Federal lands. This minimal contribution also holds steady in more grazing-dependent counties. According to this study, out of 102 counties analyzed, only 11 were found to have more than 1 percent of their total income associated with grazing on our public lands.

      Why does the federal government protect ranchers’ economic way of life at a cost to all US taxpayers? Allowing RANCHERS to use public lands is a subsidy to the livestock industry. WHY do we continue to support these subsidies, rather than encourage a functioning free market. Why does the government subsidize the ranching lifestyle - a chosen profession - over another— for example, teachers (GAO 2005). Studies have shown that despite equal or higher total grazing costs on public lands versus private lands, ranchers have been willing to pay an additional premium to buy permits to graze on public lands that supports their quality of life and their personal motives for ranch ownership.

      Ranchers try to convince the public that it is essential to subsidize grazing to preserve open spaces and stop development, but an individual rancher’s wealth and commitment to ranching as a way of life is what ultimately influences a ranchers decision to continue ranching. Population growth and demands for housing widen the disparity in land values between grazing versus development and may put some rancher, especially those facing financial pressure, in a position to sell. However, the replacement of cows with condominiums is not a foregone conclusion or the result of changes in grazing policy. Subdividing and developing ranch lands is mainly driven by market conditions—i.e. demands for land and market conditions for subdividing ranch lands is not uniform across the Western US. For example, it is not economically feasible to develop ranch lands in highly remote areas. Subsidized grazing on public lands is neither efficient or effective as a means of preserving open spaces. Zoning regulations or land purchases through conservation trusts would more effectively protect ranch land from urban sprawl and over-development.

      Grazing has contributed to, and increased the amount of, the federal government’s land management costs by eliminating grass and low-lying vegetation, grazing has contributed to increased density of conifer trees and shrubs and made these forests more prone to large, intense fires that are costly to fight. Grazing contributes to the spread of invasive noxious weed species, thereby increasing each agencies’ costs for managing their rangelands. For example, livestock transport seeds; weaken and remove native plants, such as grasses; disturb the soil; and improve invasive species growth and survival.

      Grazing, in general, and overgrazing in particular, has harmed plants and wildlife on federal lands by exposing soils to erosion, disrupting normal wildlife behavior, and reducing biodiversity. Grazing has contributed to the listing of 22 percent of federally listed threatened and endangered species (Wilcove et al 1998). Furthermore, livestock can be detrimental to native wildlife because they can transmit diseases, compete for food, disrupt normal behavioral patterns, and damage habitat. The value of forage for deer and elk competes with the forage value for cattle (Loomis et al 1989). Many invasive noxious weeds and plants can tolerate intense grazing better than most native plants, thus they can prosper and eliminate native plants needed as cover and forage by native wildlife species.

      The Service argues that grazing causes habitat degradation and disrupts normal behavior patterns of wildlife such as breeding, feeding, or sheltering (Palila v. Hawaii Dept of Land and Natural Resources 1988). Livestock management practices such as fencing, creates obstacles for many native wildlife species, limiting their movements in search of food and shelter, this includes wolves and their prey. Similarly, livestock protection plays an enormous role in eliminating native predators, which are commonly killed by private ranchers or federal agencies in order to protect their livestock. These predators occur primarily on public lands owned by all Americans and their demise should not be determined by livestock owners who are less than 5 percent of the overall population in states such as Montana. Livestock grazing is also a threat to water quality when livestock tramples stream banks, causing them to erode and increase sedimentation or spread infectious water-borne diseases to water supplies (Jacobs, 1991).

      In Montana, range allotments cover 5,407,423 acres of National Forest land and 7,839,000 acres of BLM land (a total of 13,246,423 acres). All of these range allotments are targeted for protection from predators by WIldlife Services. The BLM in Montana had more grazing in terms of billing than any other state. If not for these grazing allotments, this land would be available for use by ungulates, predators and other wildlife. However, due to the Proposed Rule, and based on Montana policies, the mere appearance of a wolf on any National Forest or BLM land (land which belongs to all US citizens) provides supposedly adequate justification to precipitate ranchers who simply ‘feel threatened’ and also allows Wildlife Services to wantonly kill every wolf they can possibly detect in these areas, using cruel, inhumane and unnecessarily painful methods.

      The Forest Service AUM fee was $0.56 in 1968, and after 4 decades it increased by an impressive $0.79 over a 40 year period. In 2012, the federal grazing fee was $1.35 per animal unit month (AUM), an astounding increase of $0.79 over a 40 year period. One would be hard-pressed to find anything other than a postage stamp which has increased so very little in cost. An AUM is the amount of grass it takes to feed a cow and her calf for a month on public lands managed by the USFS and BLM. Originally, the FS and BLM grazing fee was $0.05 per AUM for cattle, but the fee increased in 1968 to $0.56 per AUM for Forest Service permitees and $0.33 per AUM for BLM leases and permits. In 2004, the grazing fee for BLM and USFS was $1.43 per AUM and in 1980, the rate was $2.36 per AUM AND HAS NEVER EXCEEDED THIS AMOUNT! By comparison, private grazing land costs RANGE FROM $8 TO $23 per AUM (animal-unit month). In addition to federal lands, state lands allocated for grazing includes 4,250,000 acres in MT at a rate of $5.48 in FY 2012.

      Why have federal grazing fees declined, while grazing fees on private lands have increased by 78 percent? The fact is, that Federal grazing fees fall short of bringing in sufficient revenues to cover the costs of administering grazing programs administered by the BLM and the U.S. FS by $115 million, according to the 2005 GAO Report. That means that every US citizen subsidizes every rancher who uses a federal range allotment on our public lands. FS mandate is to manage almost 450 million acres for multiple uses, including timber harvest, recreation, grazing, minerals, water supplies and water quality, as well as wildlife habitat, but on the losing end is wildlife, as usual.

      Maintaining unreasonably low grazing fees enables ranchers to stay in production. BLM and FS grazing fees are lower than fees charged by any other Agencies, States, and ranchers because it was established to support the Western Livestock Industry (GAO 2005). None of the federal agencies use an approach that recovers their administrative or range management expenditures.

      Grazing is allowed on BLM and FS lands to foster economic development for private ranchers by providing these ranchers access to additional forage. Access to federal forage increases the total forage available to ranchers, enabling them to increase the number of livestock they can support and sell. Meanwhile, the AMerican public subsidizes these livestock owners who are free to kill every wolf the perceive as a threat. Never mind that those wolves are a National treasure and a part of our national heritage that more than 70 percent of Americans want to retain for future generations to enjoy and admire.

      Ranchers may renew their permits or leases indefinitely, effectively adding forage, and value to their operations, while their livestock damages OUR public resources, OUR wildlife habitat, OUR threatened and endangered species, and OUR water quality. Federal expenditures for grazing are extremely high while the fees are far too low, thereby the individual taxpayer supports increased grazing and deterioration of range conditions on our public lands. The BLM and FS spends our funds, our tax dollars, to support grazing, including, but not limited to: managing personnel, budgets, permits, vehicles, leases and grazing allotments, assessing resource conditions on range allotments, monitoring, noxious weed management (associated with livestock use), building and maintaining their fences, developing their water sources, fencing out our riparian areas to protect them from cattle; seeding to improve forage for livestock and implementing other range management projects to benefit ranchers. On top of this, USDA’s Wildlife Services removes predators (wolves) on all of the rangelands we, the American taxpayers all own, simply because the wolves may potentially threaten livestock that happen to be on our public lands; more than $5 million dollars was spent in fiscal year 2004 to conduct rangeland activities on public lands. In addition to the US Forest Service and BLM, USDA’s Natural Resources Conservation Service, conducts water quality projects and range improvement work related to grazing, so we fund fencing maintainance for livestock owners who want us to allow them to kill wolves wherever they occur. Why don’t the ranchers maintain their own fences? Why don’t they take any responsibility instead of our tax dollars being used to support ranchers who freely choose that lifestyle and the western livestock industry - at a loss to each and every tax payer.

      Federal agencies collected a total of about $21 million from fees charged for grazing permits and leases in FY 2004—this is less than one-sixth of the expenditures needed to manage grazing land; the largest amount of funds, $17.5 million in grazing receipts, was collected by the BLM and FS. Of that, only $8.8 million was returned to Range Improvement Funds

      These grazing programs jeopardize wolf recovery and adversely modify the habitat of their prey. Even the EPA provides grant money to states (under section 319 of the Clean Water Act) to improve watersheds by reducing non-point source pollution from increased runoff and sedimentation due to livestock grazing. Why is it that we, the taxpayers, spend our money to fund 5% of the population to use our land at less than fair market value and justify killing wolves to protect their livestock that use our land? The ranchers profit from this, while we lose money on range allotments and wolves lose their lives. Is this what most Americans want? Studies show that more than 70 percent of Americans support wolf recovery. How, then, can this subsidy and wolf killing be justified?

      In FY 2004, BLM and FS spent $58.3 and $132.5 million dollars, respectively, on range improvement grazing activities (GAO 2005), all at a loss. Obviously, these grazing programs pose a threat to wolves as well as water quality and they are a waste of our taxpayer dollars.

      In FY 2004, the FS and BLM spent about $132.5 million in direct and indirect expenditures to support grazing activities on federal lands. including such things as managing permits and leases, monitoring resource conditions on grazing allotments, assuring permit and lease compliance, and implementing range improvements such as developing water sources and constructing fences. The agencies also spent funds on activities that indirectly supported grazing, such as management, budget, personnel and the removal of predators, such as wolves, from all grazing lands.

      Ranchers do not obtain title to federal lands through their grazing permits and leases, nor do they have exclusive rights or access to our federal lands, which are supposedly managed for multiple purposes and multiple uses...and yet in Montana, ranchers are treated as the exclusive owner of our public lands with their belief in their own ultimate right to shoot any wolf that crosses into ‘their’ range allottment, despite the fact that these lands belong to all Americans. MT ranchers are unclear as to what their rights are on public lands and MT state does not appear interested in illuminating them to the fact that wolves are a public resource, and not just objects for target practice.

      The Service allows livestock grazing on 450,000 acres of National Wildlife Refuge lands in Montana...so even on refuge lands, lands that are supposed to provide a refuge for wildlife, a rancher can shoot wolves? Is there nowhere safe for a wolf to exist in the USA?

      The grazing permits and leases that the 10 federal agencies manage generated a total of about $21,000,000 from fees charged in fiscal year 2004—the real cost of the expenditures required to manage grazing in one year was 126,000,000. The grazing permits and leases the ten federal agencies manage generated a total of about $21 million from fees charged in fiscal year 2004—or less than one-sixth of the expenditures to manage grazing

      According to the GAO Federal Grazing Report (2005), grazing fees generate less than one-sixth of the expenditures required to manage grazing on federal lands. The AUM fee doesn’t recover agency expenditures or the fair market value of forage. Furthermore, these fees are much lower than fees charged by private ranchers. As a result, BLM’s and Forest Service grazing receipts fell short of their expenditures on grazing in 2004 by about $115 million. To make matters worse, BLM and Forest Service fees decreased by 40 percent from 1980 to 2004, while grazing fees charged by private ranchers increased by 78 percent during the same time period.

      If the purpose of the fee were to recover expenditures, the BLM and Forest Service would need to charge from $7.64 to $12.26 per AUM. Obviously, the purpose is NOT to gain a fair market value because if it were so, the agencies’ fees would be consistent with those charged on private lands. This equates to a governrnent subsidy of ranchers so that their livestock can exploit public lands while OUR wolves pay the price with their lives so that ranchers can use our public lands which are paid for by our tax dollars each year. Do Americans want to pay for ranchers to use our public lands and then kill our wolves that would be preying on our deer and elk that originally inhabited these lands long before ranchers ever apppeared on the continent and so readily displaced these animals with their own livestock.

      Th3 40 percent drop in fees charged per AUM compares with a 78 percent increase in grazing fees on private lands. The fee brings in revenues that fall far short of the costs of administering grazing by the Bureau of Land Management and the U.S. Forest Service by $115 million, according to the 2005 GAO report.

      In 2012, there were 2.5 million cows in Montana, according to the USDA 212 cattle inventory. BLM grazing in Montana supports $32.9 million worth of cattle, according to USDI statistics. The ecological cost is ruined stream courses, noxious weed-infested meadows, displaced wildlife and the loss of an ecosystem that previously dominated Montana’s landscape.

      Montana has about 4,000 ranchers with grazing leases on BLM land and 1,000 leases on Forest Service land; some ranchers hold rights with both agencies. It is illegal to log in wilderness areas, but the government still allows grazing - grazing is the one thing that gets a free ride.

      The newly calculated grazing fees, determined by a congressional formula applies to more than 8,000 permits administered by the Forest Service and nearly 18,000 grazing permits and leases administered by BLM.

      ECOLOGICAL COSTS OF GRAZING

      Cattle destroy native vegetation, damage soils and stream banks, and contaminate waterways with fecal waste. After decades of livestock grazing, once-lush streams and riparian forests have been reduced to flat, dry wastelands; once-rich topsoil has been turned to dust, causing soil erosion, stream sedimentation and wholesale elimination of aquatic habitats; overgrazing of fire-carrying grasses has starved some western forests of fire, making them overly dense and prone to unnaturally severe fires WHICH WE, THE TAXPAYERS ALSO FUND IN OUR FIRE FIGHTING EFFORTS.

      Keystone predators like the grizzly bear and Mexican gray wolf were driven to extinction in southwestern ecosystems by “predator control” programs designed to protect the livestock industry. Adding insult to injury — and flying in the face of modern conservation science — the livestock industry remains the leading stodgy opponent to otherwise popular efforts to reintroduce species like the Mexican gray wolf in Arizona and New Mexico.

      ECONOMIC COSTS OF GRAZING

      It isn’t simply the direct subsidies and federal assistance programs that public land livestock operators rely on. The federal grazing fee is unreasonably low, creating a de facto subsidy for cattle owners. The western livestock industry would evaporate as suddenly as fur trapping did if it had to pay fair market rates for the services it acquires free of charge from the federal government and our tax dollars.

      Private, unirrigated rangeland in the West rents out for an average of $11.90, while monthly grazing fees on federal lands are currently set at a paltry $1.35 per cow and calf. Despite the extreme damage done, western federal rangelands account for less than 3 percent of all forage fed to livestock in the United States. If all livestock were removed from public lands in the West, in fact, beef prices would be unaffected.

      Efforts to reform overgrazing on public lands in the West have continually been fought. Wildlife Services work has not protected endangered species - the FS and BLM have not removed cattle from hundreds of vulnerable riparian areas in our National Forests. Battles in court that intend to increase the federal fee for livestock grazing on public lands to an amount that’s fiscally responsible and less ecologically harmful is being fought against by ranchers. Legal action has compelled the Forest Service to do an environmental impact statement on the impacts of grazing on more than 13 endangered species; in the late 1990s, the Bureau of Land Management was persuaded to remove cattle from all or part of 32 allotments and the Forest Service removed cattle from 250 miles of streams on 52 allotments.

      NGO work helped stop domestic sheep grazing on 7,500 acres in and around the greater Yellowstone ecosystem to protect grizzly bears, lynx, wolves and bighorn sheep; they also halted grazing on a quarter-million acres of Oregon’s Malheur National Forest to protect steelhead trout. In 2011, federal appeals stopped grazing on 33,000 acres of National Forest land in Arizona. NGO’s sued the federal government to compel it to fix agency budget woes by reforming or eliminating the grazing program, which loses money just as rapidly and consistently as it destroys habitat. Unfortunately, in 2011 the Obama administration announced it was refusing to increase grazing fees to levels reflecting grazing’s true financial and environmental costs.

      Meanwhile, a lonely wolf pack was eliminated by an overzealous rancher who lived near Twisp, WA. The rancher conspired to kill a wolf pack (Twisp rancher convicted of conspiring to kill a wolf, reports dead calf( Mehaffey, April 29, 2013, Wenatchee World) “A Twisp cattle rancher who admitted last year that he had conspired to kill a wolf and ship its pelt to Canada reported finding a dead calf that he suspected might have been killed by a wolf on his property. Department of Fish and Wildlife officials say their preliminary finding was that this man, Bill White’s calf was not killed by a wolf.” So here we go again, the wolf isn’t even delisted and ranchers in Washington state are already killing them in defense of cattle despite the FACT that their livetock was NOT even killed by a wolf.

      REPORT THIS COMMENT:
    • Paula Phillips SEVERNA PARK, MD
      • 9 months ago

      Protection of wildlife is one of the marks of a civilized society. Mexico should count itself among the advanced, civilized societies and show respect for natural life.

      REPORT THIS COMMENT:
    • Lorna Soto ROWLETT, TX
      • 10 months ago

      JUSTICIA POR LOS LOBOS!

      Protect The Mexican Gray Wolf

      REPORT THIS COMMENT:
      • 10 months ago

      I LOVE WOLVES

      REPORT THIS COMMENT:
    • Kylie S NEW YORK CITY, NY
      • 10 months ago

      Wolves are an important part of the environment.

      REPORT THIS COMMENT:

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