HERE IS FURTHER EXPLANATION OF PRIOR "TALKING POINTS " SO THERE IS A FURTHER UNDERSTANDING OF THE ISSUES AT STAKE AND THE CONTROVERSIES.....
In response to petitions filed by Sierra Club, Center for Biological Diversity and the Humane Society of the United States, the U.S Fish and Wildlife Service is considering restoring the Endangered Species Act protections to gray wolves that were removed by the Trump Administration.
The U.S. Fish and Wildlife Service wants to hear from you!
To comment go to: www.regulations.gov
Search for Docket Number: FWS-HQ-ES-2021-0106
Click on “Comment”.
Deadline for submitting comments is December 16th, 2021.
The U.S. Fish and Wildlife Service is required to make listing determinations “solely on the basis of the best scientific and commercial data available to [it] after conducting a review of the status of the species and after taking into account “existing efforts to protect the species without reference to the possible economic or other impacts of such a determination. “
Please submit comments in support of restoring ESA protections to gray wolves.
Please consider using the below talking points to write and submit comments in your own words.
Detailed explanation of talking points is provided below.
1. CURRENTLY GRAY WOLVES OCCUPY ONLY ABOUT 15% OF THEIR HISTORIC RANGE IN THE U.S. ALTHOUGH ABUNDANT SUITABLE HABITAT EXISTS. CURRENTLY, GRAY WOLF POPULATIONS ARE A SMALL FRACTION OF THEIR HISTORIC POPULATION SIZE AND THEIR EXISTENCE IS THREATENED BY BOTH “OVERUTILIZATION FOR COMMERCIAL, RECREATIONAL PURPOSES” ANDINADEQUACY OF EXISTING PROTECTION”.
2. GRAY WOLVES FACE IMMEDIATE THREAT OF EXTINCTION FROM STATE-SANCTIONED HUMAN HUNTING AND TRAPPING AND QUALIFY FOR ENDANGERED SPECIES ACT PROTECTIONS ACROSS ALL OR A SIGNIFICANT PORTION OF THEIR RANGE.
3. WITHOUT REINSTATEMENT OF ESA PROTECTIONS AND DUE TO INADEQUACY OF EXISTING PROTECTIONS, WOLVES WILL BE REDUCED TO A SMALL FRACTION OF WHAT IS NEEDED FOR THEIR BIOLOGICAL RECOVERY AND SURVIVABILITY.
Photo: Wolfgang Kaehler/LightRocket -Getty Images
4. WOLF POPULATIONS MUST BE CONNECTED TO BE VIABLE OVER THE LONG TERM. THE GAUNTLET OF GUNS AND TRAPS THAT NOW CHARACTERIZES WOLF MANAGEMENT IN THE NORTHERN ROCKY MOUNTAIN STATES PREVENTS DISPERSAL AND INHIBITS CONNECTIVITY.
5. WOLVES CAN INITIATE CASCADES OF ECOLOGICAL EFFECTS THAT ENHANCE ECOSYSTEM FUNCTION AND PROCESS, BUT ONLY IF THEY ARE PRESENT IN ECOLOGICALLY EFFECTIVE NUMBERS AND PACKS ARE UNHARMED AND WIDELY DISTRIBUTED.
6. WOLVES CONTROL THEIR OWN POPULATIONS: CULLING IS NOT NEEDED AND IN FACT DESTABILIZES WOLF PACKS WHICH REDUCES THEIR ECOLOGICAL EFFECTIVENESS AND SURVIVABILITY.
7. ECONOMIES THRIVE WHERE WOLVES ARE PRESENT AND PROTECTED. WITHOUT ESA PROTECTION, YELLOWSTONE WOLVES THAT HAVE MIGRATED OUT OF THE PARK IN PURSUIT OF THEIR UNGULATE PREY AND OUT OF THE PROTECTED AREA OF THE PARK, HAVE BEEN KILLED BY HUNTERS AND TRAPPERS, REDUCING THE SURVIVABILITY OF POPULATIONS IN THE PARK AND UNDERMINING THE LOCAL ECONOMY.
8. LIVESTOCK PRODUCERS AND WOLVES CAN AND DO SUCCESSFULLY COEXIST. WITHOUT ESA PROTECTION, LIVESTOCK PRODUCERS HAVE LITTLE INCENTIVE TO IMPLEMENT CONFLICT AVOIDANCE STRATEGIES.
9. UNGULATE HERDS HAVE INCREASED, AND ECOSYSTEM HEALTH HAS IMPROVED WHERE WOLVES ARE PRESENT IN ECOLOGICALLY EFFECTIVE POPULATIONS AND WHERE FAMILY STRUCTURE IS NOT DISRUPTED BY HUMAN RECREATIONAL KILLING.
26
1. CURRENTLY GRAY WOLVES OCCUPY ONLY ABOUT 15% OF THEIR HISTORIC RANGE IN THE U.S. ALTHOUGH ABUNDANT SUITABLE HABITAT EXISTS.
a. Wolves are absent from a number of expansive ecoregions within the bounds of the Western Distinct Population Segment area where they originally roamed: breeding populations of wolves are entirely absent from the Great Basin ecoregion; the Colorado Plateaus ecoregion currently lacks an extant wolf population: the Wyoming Basins ecoregion also lacks a breeding population of wolves, although a pack of wolves was present in the Irish Canyon area of northwestern Colorado during 2020 before disappearing under suspicious circumstances in early 2021; the Coast Range ecoregion of the Pacific Northwest, along with the Puget Lowlands, Klamath Mountains, and Willamette Basin ecoregions, lie to the west of the Cascade Mountains crest, and have yet to recover wolf populations sufficiently large to be secure from the threat of extinction.
b. With gray wolves occupying just over 2% of their former range in the conterminous United States and less than 15% of
their habitat in the west, and at a tiny fraction of their former number, it is questionable whether recovery has been
1
achieved . The large historic population size of about 380,000 grey wolves in the west, implied by genetic data, provides a
10. “BLOOD DOES NOT BUY GOODWILL”
WOLVES DOES NOT INCREASE TOLERANCE OF WOLVES BUT RATHER INCREASES POACHING. RESTORING ENDANGERED SPECIES ACT PROTECTIONS IS ESSENTIAL TO PREVENTING RECREATIONAL KILLING AND POACHING.
. SCIENCE DOCUMENTS THAT ALLOWING RECREATIONAL KIILLING OF GRAY
striking contrast to restoration goals in the western conterminous US 2 bringing into question the judgement of reducing wolf
1 populationnumbersjustadecadeaftertheyhavebeenreintroduced .
3
c. U.S. FWS uses the Species Status Assessment Framework to evaluate a species status . which follows the conservation
principles of resiliency , redundancy , and representation (the 3Rs) to evaluate the status of a species. The U.S. FWS’s guidanceinstructs that all the 3Rs – resiliency, redundancy, and representation -must be met for a species to be delisted.
o Representation: The species occurs across all ecological “contexts” or communities, fulfilling the ESA’s geographicrepresentation mandate.
o Resiliency: Refers to population characteristics (such as genetic diversity) that foster long term survival despite stochastic environmental variation, threats, and disturbance events.
o Redundancy: Refers to multiple populations in different ecological “settings” to reduce risk of extinction from catastrophe.
At the time of delisting, gray wolves did not meet these criteria and should not have been delisted. With delisting, state hunting and trapping programs have further reduced wolf representation, resiliency and redundancy.
Gray wolf populations do not meet these criteria now.
d. To enable a resilient, redundant, and representative meta- population of gray wolves that can survive over the long-term,
ESA protections for gray wolves must be restored, as required by the Service’s own guidelines,
2. GRAY WOLVES FACE IMMEDIATE THREAT OF EXTINCTION AND QUALIFY FOR ENDANGERED SPECIES ACT PROTECTIONS ACROSS ALL OR A SIGNIFICANT PORTION OF THEIR RANGE.
• Federal responsibility for protecting gray wolves under the experimental population provisions of the Act would continue
until formal delisting rule making procedures are completed. In accordance with the Act, delisting may occur when analysis of the best available scientific and commercial information shows that gray wolves are no longer threatened with extinction due to: (1) The present or threatened destruction, modification, or curtailment of its habitat or range, (2) Overutilization for commercial, recreational, scientific, or educational purposes; (3) disease or predation, (4) inadequacy of existing regulatory mechanisms, and (5) other natural or manmade factors.
3. WITHOUT REINSTATEMENT OF ESA PROTECTIONS, WOLVES WILL BE REDUCED TO A SMALL FRACTION OF WHAT IS NEEDED FOR THEIR BIOLOGICAL RECOVERY AND SURVIVABILITY. ESA protection for wolves was essential to wolf recovery when wolves were reintroduced to Yellowstone National Park and Idaho in 1995 and 1996. Wolves have not recovered and instead, because of state laws that have liberalized recreational killing, restoration of ESA protections remain essential to their recovery.
“Since the US Fish and Wildlife Service stopped providing oversight and requiring mandatory reports, there’s been a major attack on the wolf population” (Suzanne Stone, 2020, Cofounder Wood River Wolf Project).
Newly passed laws in Montana and Idaho are intended to reduce wolf populations by 80% and 90%, throwing us back 100 years to a time when wolves were driven to near extinction.
In Idaho there is a year-round hunting and bounties on wolves, which don’t exclude nursing females and their young pups.
4
Within a 12-month period ending on June 30, 2020, alone, 570 wolves were killed in Idaho . Nearly 3,500 wolves have
5 been killed in Idaho, Montana, and Wyoming since 2011 .
• Wyoming law classifies wolves as “predatory animals” that can be killed on sight 365 days a year across 85 percent of the state without regard for numbers or method of kill. The only requirement is notification to the Wyoming Department of Game and Fish within ten days. Except for Yellowstone National and Grand Teton National Parks, the other 15% of the state, near the Tetons, is classified as a “trophy zone” where wolves are classified as “game animals” and recreationally killed from October 1 to December 31. Trophy Zone hunts are subject to bag limits and hunting seasons; in 2020, a total of
6
31 of approximately 147 total wolves in this area were killed
.
In Oregon, in September of 2021, the Oregon Department of Fish and Wildlife (ODFW) authorized lethal action on the entire Lookout Mountain wolf family: an aerial sharpshooter for ODFW killed the breeding male, a yearling male, and a 5- month- old pup but did not kill the breeding female. However, ODFW did authorize ranchers to kill wolves on their land.
Killing wolves can destabilize packs and potentially lead to more depredations on livestock. “This gives the state more reason to kill more wolves. It becomes this vicious cycle” (Suzanne Stone, 2020, Wood River Wolf Project).
With removal of ESA protection and under state management, wolf populations in the west are declining toward
5
extinction. Anthropogenic mortality rate of about 25% typically yields a declining population
and Montana showed indications of instability as early as 2013 – around the time that states took over management. The International Union for Conservation of Nature Red List Criterion C1, classifies a population segment as endangered if it
7
states reduced year-end wolf populations by 40-50% in 2019, close to double acceptable level of anthropogenic mortality.
4. WOLF POPULATIONS MUST BE CONNECTED TO BE VIABLE OVER THE LONG TERM. THE GAUNTLET OF GUNS AND TRAPS THAT NOW CHARACTERIZES WOLF MANAGEMENT IN THE NORTHERN ROCKY MOUNTAIN STATES PREVENTS DISPERSAL AND INHIBITS CONNECTIVITY.
Genetic exchange between populations is essential to healthy wolf populations.
Peer-reviewed science finds that long-term prospects for recovery of gray wolves in the western US may hinge on wolves
8
Wolves must be able to disperse and connect with other populations to remain viable over the long term.
Current gray wolf management in the Northern Rockies and in New Mexico and Arizona inhibits dispersal and breaks the
connections essential for dispersal and commensurate genetic viability.
Mexican gray wolves must be able to move north habitat because within the historic range is no longer sufficient for
recovery. Due to both human impacts on habitat, and to climate change, habitat in the southern portion of Mexican wolf
range has decreased and is likely no longer sufficient for recovery9
WITHOUT ESA PROTECTIONS WOLVES HAVE BEEN CAUGHT IN HUNTER AND TRAPPER CROSSFIRE – attempting to
holds fewer than 2500 individuals and has declined by ≥20%
. Liberal hunting and trapping policies in Idaho and Montana
being able to successfully disperse between widely separated populations
formerly widely distributed species, like the wolf, cannot be successfully restored in isolated populations in a few parks and expect them to remain genetically healthy.
disperse but failing under an onslaught of bullets and traps.
. Wolf populations in Idaho
. Findings from this research imply that a
5. WOLVES CAN INITIATE CASCADES OF ECOLOGICAL EFFECTS THAT ENHANCE ECOSYSTEM FUNCTION AND PROCESS, BUT ONLY IF THEY ARE PRESENT LON-TERM IN ECOLOGICALLY EFFECTIVE NUMBERS, AND PACKS ARE INTACT AND WIDELY DISTRIBUTED.
• Where wolves are present long-term in ecologically effective numbers and widely distributed, they benefit the entire
community of wildlife. Wolves keep large ungulates moving and vigilant a thus preventing overbrowsing which improves
10
species also recover. Recovery of native wildlife and plant species enhances biological diversity which helps mitigate our
11
management practices that led to their near extermination and will again decimate wolf populations.
o Between 2009 and 2020 Wildlife Services, along with hunters and trappers, have reported killing at least 2,400
12
that wolves have brought to ecosystem and herd health are being disabled.
6. WOLVES CONTROL THEIR OWN POPULATIONS: CULLING IS NOT NEEDED AND IN FACT DESTABILIZES WOLF PACKS RESULTING IN REDUCING THEIR ECOLOGICAL EFFECTIVENESS. Both within-pack strife and between-pack strife moderates wolf populations abundance to create a dynamic balance between wolf and prey populations. Numerous investigators have reported on factors that regulate wolf populations, bringing into question the need to cull them to prevent them from
aspen forest health and riparian habitat and stream health
. When vegetation recovers from overbrowsing, other native
warming climate by restoring essential ecosystem cycles and services
• WITHOUT ESA PROTECTIONS, states including Idaho, Montana, and Wyoming have reverted to 19th century wolf
wolves in Montana
• WITHOUT ESA PROTECTIONS DECADES OF RECOVERY PROGRESS HAS BEEN REVERSED and the many beneficial effects
.
expanding their populations beyond an arbitrary socially determined carrying capacity
13,14,15,16, 17, 18.
More recently nine scientists examined the question of population control among wolves and, after acknowledging available
food affects a number of vital factors, concluded that “adult survival is the most important vital rate to wolf population
19
growth.” . Their findings provided “strong evidence that social factors play a key role in driving wolf mortality rates in
Yellowstone, which leads to the conclusion that if wolves were not territorial, there would be more of them on the landscape.” .
Protecting intact wolf families maintains the evolved social interdependencies that enable effective and sustainable
predator-prey relationships .
Human persecution of wolves (hunting, trapping, poisoning etc.) disrupts wolf family structure, behavior and balance.
Consequently, the wolf family’s ability to hunt and perform their ecological role of moderating populations of large
ungulates and enhancing biological diversity, is diminished.
Without ESA protection, liberal hunting and trapping of wolves has dramatically reduced wolf populations, destabilized
family structure and diminished the beneficial effects that intact wolf families can have on ecosystem health and biodiversity.
o Consequences of killing wolves include the effects on the social dynamics resulting from the loss of key pack members: if an alpha female is killed, that pack is unlikely to reproduce that year. If a pack’s only big male is killed, that may result in diminishing the pack’s food base, because big males are key to killing prey that are located and chased down by other pack members (Smith, pers. comm.).
.
.
o “Should we control wolves?” Biologist Bob Hayes provides his biological opinion: “I spent eighteen years studying the effects of lethal wolf control on prey populations. The science clearly shows killing wolves is biologically wrong.” As I began to better understand the wolf, I developed a clear answer to my question about the effectiveness and moral validity of lethal wolf control programs.” *** “I can now say the benefits of broad scale killing of wolves are far from worth it - not to moose, caribou, Dallʼs sheep or people. It should never happen
20 again” .
7. ECONOMIES THRIVE WHERE WOLVES ARE PRESENT AND PROTECTED. WITHOUT ESA PROTECTION, YELLOWSTONE WOLVES THAT HAVE MIGRATED OUT OF THE PARK IN PURSUIT OF THEIR UNGULATE PREY AND OUT OF THE PROTECTED AREA OF THE PARK, HAVE BEEN KILLED BY HUNTERS AND TRAPPERS, REDUCING THE SURVIVABILITY OF POPULATIONS IN THE PARK AND UNDERMINING THE LOCAL ECONOMY.
In 1995, the first-year wolves were transplanted to the park, 130 tour companies operated in the park with commercial useauthorizations (CUAs). By 2019, over 300 CUAs had been issued.... The rise in Yellowstone’s wildlife-watching industry follows a general trend nationally, which saw a 28% increase in wildlife-watching activities since 2001. By 2016, 86 million people
19
21
were watching wildlife, and their associated expenditures totaled over $70 billion
.
The annual economic impact of wolf restoration was estimated in 2005 at $35.5 billion
2005 was 2,835,651, but by 2017, park visits had risen 145% to 4,116,525. An estimate of the annual economic impact, adjusted for 23% inflation over this period, is $65.5 million annually. This economic benefit is based on just a park wide total of 94 wolves in 2020, of which 55 lived on the northern Yellowstone elk winter range, where most wolf observation takes place. With some simple math, dividing net dollars by 94 wolves gives each wolf an average value of $69,688 per year to the surrounding counties. Furthermore, wolf watchers help spread these economic benefits over time, as they visit outside the
19
peak summer season and stay longer than most Yellowstone visitors.”
.
“Legal and illegal killing of animals near park borders can significantly increase the threat of extirpation for populations living within ecological reserves, especially for wide-ranging large carnivores that regularly travel into unprotected areas; Our results indicate that even in a relatively large, protected area, human harvesting outside park boundaries can affect evolutionarily
17
important social patterns within protected areas”
.
8. LIVESTOCK PRODUCERS AND CARNIVORES CAN AND DO SUCCESSFULLY COEXIST. WITHOUT ESA PROTECTION,
LIVESTOCK PRODUCERS HAVE LITTLE INCENTIVE TO IMPLEMENT CONFLICT AVOIDANCE STRATEGIES.
• In the Northern Rocky Mountains, the total cattle in wolf country in 2015 numbered 1,980,600 . Confirmed cattle losses of
22
Project, sheep losses to wolves = O.02% with no wolves killed. In Montana’s Tom Miner Basin, wolf conflict preventionstrategies resulted in 4 years with no wolf depredations on cattle.
cattle to wolves in 2015 in the NRM totaled 148
• Where conflict avoidance strategies are properly implemented, losses often went to zero. At Idaho’s Wood River Wolf
.
. Visitation to Yellowstone during
9. UNGULATE HERDS HAVE INCREASED, AND ECOSYSTEM HEALTH HAS IMPROVED WHERE WOLVES ARE PRESENT IN ECOLOGICALLY EFFECTIVE POPULATIONS AND WHERE FAMILY STRUCTURES IS NOT DISRUPTED BY HUMAN RECREATIONAL KILLING.
In the Northern Rocky Mountain wolf country, elk populations have increased by 40,000, and elk hunter success is better
than in states, such as Colorado, where there are no wolves.
Elk numbers exceed state goals in Idaho, Wyoming, and Montana: Idaho elk are above goal in 17/22 elk management
23,24,25
10. “BLOOD DOES NOT BUY GOODWILL”
GRAY WOLVES. Legal culling of wolves has been conjectured to increase “social tolerance” among local communities.Instead, research documents that lethal removal has been correlated with increased levels of poaching: “granting
25
zones; Wyoming elk are 29% over goal; and Montana elk are 50% over goal
• ESA PROTECTION OF WOLVES WAS ESSENTIAL to wolf recovery and thus to the recovery of ecosystems that support
herds of ungulates and biological diversity.
26
management flexibility for endangered species to address illegal behavior may instead promote such behavior”
allowing public recreational killing does not increase “social tolerance” for the species or reduce poaching. Quite the opposite, researchers found that the delisting of wolves in Wisconsin, triggering the onset of sport hunting, was accompanied by a
27
significant spike in illegal shooting LITERATURE CITED
.