December 5, 2021
U.S. Fish and Wildlife Service:
Concerning Docket No. FWS-HQ-ES-2021-0106
Dear U.S. Fish and Wildlife Service:
Actions by the Trump Administration in October of 2020 have placed the future of wolves in the grasps of wolf proponents and the courts. Anti-wolf advocates have wished to lessen the influence of the species upon the landscape for years. And now, what some believe was a political decision by the previous administration, they have a chance to succeed. The killing of hundreds of wolves in Wisconsin in February of 2021 is one example. Excessive wolf killing is on-going in states of Idaho and Montana. It is obvious to the Gallatin Wildlife Association that these actions are not based upon science, but of hate and stereotypical fears of predators. Now the U.S. Fish and Wildlife Service (USFWS) has taken on the responsibility to review the status of wolves to determine if a policy of relisting needs to be in place.
The Gallatin Wildlife Association (GWA) is urging the USFWS to restore protections to the gray wolf for many reasons, but the most important is to maintain their traditional role as an apex predator, one which contributes balance to the ecology of the wild.
GWA is a local, all volunteer wildlife conservation organization dedicated to the preservation and restoration of wildlife, fisheries, habitat and migration corridors in Southwest Montana and the Greater Yellowstone Ecosystem, using science-based decision making. We are a nonprofit 501(c)(3) organization founded in 1976. GWA recognizes the intense pressures on our wildlife from habitat loss and climate change, and we advocate for science-based management of public lands for diverse public values, including but not limited to hunting and angling.
The Trump Administration argued for the delisting of wolves based upon the fact that recovery numbers had exceeded goals set in 1978. Those goals were established 43 years ago. While the actual meeting of goals is questionable, the subject is really irrelevant. The original 1978 wolf population goals were arbitrary and politically determined. Rationale for those population numbers were not based upon the possibility of a changing science of today nor did it allow for the possibility of a changing landscape, specifically a changing climate resulting in changing migration shifts of prey species.
Trying to find accurate and current population numbers for wolves in the northern Rocky Mountains is as difficult as trying to find a wolf in the wild itself. According to the USFWS1, there are 1,782 wolves in the three states of Wyoming, Idaho and Montana, but those population numbers are based upon 2014 statistics. According to Wildlife Management Institute2, there were a little over 3,100 wolves in the three states of Montana, Idaho and Wyoming during the midwinter of 2020. Yet both of these estimates are far below what the application of the “minimum viable population” (MVP) concept necessitates.
In addition to the MVP concept, the Center for Biological Diversity3 draws this conclusion from their analysis of wolf habitat.
“….we used 27 studies that model wolf habitat in different regions to create a single map. Based on this analysis, there is up to 530,000 square miles of suitable wolf habitat in the United States, only roughly 171,000 square miles of which is occupied, demonstrating that wolves currently occupy only about 30 percent of existing suitable habitat….. According to the studies, these areas are capable of supporting a minimum of 5,000 wolves, which would nearly double the existing wolf population.”
To inform the USFWS on the biological sciences seems analogous to the scenario of a student teaching the teacher, but this seems to be where we’re at in our society today. There have been many studies on the subject of “minimal viable populations”, a concept that is widely practiced and applied in wildlife management to prevent species in the wild from losing genetic viability and going extinct. According to its application, MVP indicates that up to 5,000 wolves could inhabit the northern Rockies of Wyoming, Idaho and Montana. That is double or nearly so based upon the current population trends we know today. While a few wildlife managers may not have complete confidence in MVP applications, they should not be dismissed either.
In a scientific article entitled “Biogeographic and Genetic Factors in Northern Rockies Wolf Populations”, Dr. Ken Fischman4, who holds a PhD in Genetics, states this at the end of his paper.
“Considering all the evidence accumulated, it is clear that the wolf management plans of the federal and state agencies are not based on sound scientific and genetic data or theory. If they are carried out as presently planned, they will undoubtedly lead to genetic impoverishment and possibly to a second extinction of wolves in the Rocky Mountain region.”
Genetics must not be left out of the equation concerning species viability, yet we suspect such discussions were missing from wolf delisting. An interesting read can be found in the research: “How many wolves does it take to protect the population? Minimum Viable population size as a technology of government in endangered species management (Norway, 1970s-2000s)”. According to a scientific paper found on line, Researchgate.net, a paper written by Hakon B. Stokland5 of Norwegian University of Science and Technology, told of an interesting series of events. The story unfolded as a result of the Norwegian government trying to apply MVP to wolves.
This brings us back to the genetics concern. While unintended consequences occurred, such as the measure of viability being revisited in the nation’s court structure, some good science came from that episode which was published in May 2016.
“Biologist at SKANDULV, a project established in 2000 to improve cooperation between Norwegian and Swedish wolf research, saw the difference in estimates of viability revealed in court as highly problematic. In response, they made another attempt to scientifically determine the minimum viable population size of Scandinavian wolves. SKANDULV organized a closed workshop on viability and the Scandinavian wolf population in 2002…..
The panel consisted of international expert biologist: three geneticists, one population biologist, and two wolf ecologists. In addition, Scandinavian biologists, nature managers, and NGO representatives participated…….
The genetic aspects of viability were central to the discussions at this workshop, and the loss of genetic variation in terms of heterozygosity was a topic at the core of these discussions. The geneticists stated that a common criterion for genetic viability was protection of 95-98% of the genetic variation of a population over 100 years, and the panel agreed, in the end, to a definition of genetic viability of protecting, at minimum, 95% of the genetic variation over 100 years. There was some debate over this percentage, in which the ecologists seemed ready to accept a lower percentage (as low as 75 %). The geneticists, however, argued that empirical data from captive populations indicated a critical limit of 95%.”
So, with this in mind, has these determinations been made by the USFWS or other scientists either inside or outside of government for wolf populations in the Northern Rockies or anywhere in the US? Was there even a debate about this issue, a discussion? GWA does not see how a removal of 85% or 90% of the wolves in Montana and Idaho (respectively), as is proposed by these two states, can be done scientifically and/or humanely without jeopardizing the long-term health effect on wolves.
But there is more. Because of climate change, the science of species recovery has changed too. GWA would like to refer the USFWS to the following scientific summary published by the Ecological Society of America. In the Winter 2016 edition, Number 20, entitled “Species Recovery in the United States: Increasing the Effectiveness of the Endangered Species Act”, Evans, M. Daniel6, et al, states this in the opening paragraph of his summary.
“The Endangered Species Act (ESA) has succeeded in shielding hundreds of species from extinction and improving species recovery over time. However, recovery for most species officially protected by the ESA – i.e., listed species—has been harder to achieve than initially envisioned. Threats to species are persistent and pervasive, funding has been insufficient, the distribution of money among listed species is highly uneven, and at least 10 times more species than are actually listed probably qualify for listing. Moreover, many listed species will require ongoing management for the foreseeable future to protect them from persistent threats. Climate change will exacerbate this problem and increase both species risk and management uncertainty, requiring more intensive and controversial management strategies to prevent species from going extinct.”
Hence, the gray wolf needs to be considered in this light since this species is obviously an integral link in the ecology of the wild. Conditions on the ground are forcing scientists to reconsider the recovery goals set so many years ago, believing them to be too low. It is widely known, because of climate change, that species have either shifted or modified their range, some of that due to prey migration. And then you just have the simple effects of drought alone that have placed additional pressures on all species. The Greater Yellowstone Ecosystem (GYE) has been a natural laboratory in the study of wolf impact on the natural landscape. Since their reintroduction of 1995, it is generally agreed that wolves have had an overall positive behavioral effect on elk and on other primary and secondary impacts within the ecological niche of the GYE. And now with Chronic Wasting Disease (CWD), we are learning that wolves by preying upon infected animals can play a more pivotal role in helping to curtail and mitigate the spread of that disease.
There are these quotes from scientific journals. The USFWS should be aware of such research and science in their own behalf, but none-the-less, they are presented here as well. On pages 84 and 85 in the Journal of Wildlife Diseases, Wild, A. Margaret7, et al, in an article entitled “The Role of Predation in Disease Control: A Comparison of Selective and Nonselective Removal on Prion Disease Dynamics in Deer”, there are these statements concerning the role of predation and the disease.
“Alternatively, selective predation by wolves at the same rate would result in a more precipitous drop in CWD prevalence that would culminate in disease elimination in a closed system (Fig. 1E, F). Selective predation does not allow a larger population of susceptible animals to persist relative to the nonselective case because wolves are assumed to consume more susceptible animals as infected ones become rare.
Simulation results suggested that selective predation could also dampen or eliminate the emergence of CWD in new locations (Fig. 3), adding support to speculation that the absence of large predators presents an amplification risk factor for establishment of CWD (Samuel et al., 2003).”
And from the Abstract:
“We suggest that as CWD distribution and wolf range overlap in the future, wolf predation may suppress disease emergence or limit prevalence.”
There are other scientific articles and research that highlights the value that wolves bring to the ecological integrity of our wildlands. And by wildlands, we refer to our forests, grasslands and other biomes home to wolves. The science overwhelmingly shows the critical nature that wolves have on the landscape, but we know that wolves weren’t delisted because of the success of the ESA listing. They were delisted because political actors were wishing it to be so. Political actions have no place in the determination of species viability.
This past year, GWA provided oral and written testimony before Montana State House and Senate Committee hearings over anti-wolf legislation, legislation which quickly became nicknamed “a war on wildlife”. In that legislation, it became obvious those bills were introduced by special interest groups including the trapping industry itself to increase the take on wolves by easing regulations on trapping and to introduce the legalization of snaring. All of the scientific testimony which was presented before legislators at that time was ignored. Likewise, the same could be said about the comments provided to the Montana Fish and Wildlife Commission by those arguing against the implementation and application of the new laws. GWA provided comments in both events and are available upon request.
Such is the regressive and biased political atmosphere in many states across the West. It is this atmosphere that poses a grave danger to wolves and other wildlife species and their habitat. An example of the danger to the viability of wolves can be seen in this story which recently came across our desk. Wildlife Services, a division of the Dept. of Agriculture, recently killed eight (8) wolf pups in Idaho. This story was captured and presented by The Hill magazine dated Oct. 11, 2021 by Monique Beals8. This type of story is not the exception, but is becoming the norm. With this supposedly legal action, how can wolves survive a 90% kill rate of wolves in Idaho and an 85% kill rate in Montana. This places wolves on the precipice of extinction. If wolf pups are allowed to be killed without justification, then there are no guardrails to the slaughter.
In Idaho, Governor Little has already signed into law, legislation that permits the use of night hunting with night-vision equipment, aerial gunning, and hunting from snowmobiles and all-terrain vehicles. In Montana, the story is much the same. Here Governor Gianforte has signed a law extending wolf trapping seasons, authorizing the use of snares and a wolf bounty. These laws also permit the killing of an unlimited number of wolves.
GWA finds all of these actions unscientific and lacking in ethical character, two principles which our organization tries to uphold. We believe this country does not need to institutionalize as a Nation or state, laws that attempt to defend the indefensible. This creates an ecological injustice and violates natural law.
In Summary:
GWA believes that the removal of wolf protections by the previous administration was in itself unlawful in that it violated the intent of the Endangered Species Act of 1973 (ESA). We believe the removal of the wolf from the ESA list was done in order to legalize the taking of wolves for sport or for monetary gain, directly or indirectly. Removal of species protection for personal preference, personal gain, or financial gain of others is wrong and has no place in proper wildlife management of 21st century.
We believe previous actions were wrong as they were not based upon science, ethics or proper wildlife management practices. We also believe that perhaps the ESA was violated, at least the good faith of the ESA, as the law establishes a recovery plan before approval. The latest and only Recovery Plan9 that we have found was signed in 1987, 34 years ago, 33 years before action of wolf removal was approved. The law also requires that there be a five-year monitoring plan for species. Was there any review by USFWS or other appropriate Federal Agencies in this matter based upon the new science and the new conditions on the ground as stated in these comments?
Finally, the ESA states in Public Law 100-478, enacted October 7, 1988, (102 Stat 2306)10, the following provision:
- “Directs the Secretary of Interior to develop and review recovery plans for listed species without showing preference for any taxonomic group.”
- Requires a status report to Congress on recovery plans, every two years.
- Provides for public review of new or revised recovery plans prior to final approval.
We question whether or not, any of these appropriate steps had been followed in the Trump Administration’s decision in a way that didn’t violate the intent of the law. We find, whether it be state or federal entities, the public’s will has either been ignored or willed inconsequential.
For these additional reasons stated here and for all of the scientific reasoning mentioned above, GWA fully believes the gray wolf needs to be restored and included under protections of the Endangered Species Act of 1973. It is obvious certain segments of our society are incapable of managing wildlife, especially predators in a scientific, rationale, and ethical manner. We have not relieved ourselves of the baggage that has been carried forth by multiple generations. Again, we implore those with the decision-making process, to restore protections to the gray wolf.
Thank you for this opportunity to comment.
Sincerely,
Clinton Nagel, President
Gallatin Wildlife Association
References:
1. U.S. Fish and Wildlife Service website,
https://www.fws.gov/midwest/wolf/aboutwolves/wolfpopus.htm
2. Smith, Chris, “Update on Western Gray Wolves”, Wildlife Management Institute, July 2021 Editin, Volume 75, Issue 7.
https://wildlifemanagement.institute/outdoor-news-bulletin/july-2021/update-western-gray-wolves
3. Weiss, Amaroq, Greenwald, Noah, Bradley, Curt, “Making Room for Wolf Recovery: The Case for Maintaining Endangered Species Act Protections for America’s Wolves”, Center for Biological Diversity, November 2014.
https://www.biologicaldiversity.org/campaigns/gray_wolves/pdfs/Making_Room_for_Recovery_print.pdf
4. Fischman, Ken, PhD, “Biogeographic and Genetic Factors in Northern Rockies Wolf Populations”, April 9, 2008.
http://ancientpathwaystoasustainablefuture.org/1wolves/biogeographic-and-genetic-factors-in-northern-rockies-wolf-populations-2/
5. Stokland, Hakon B., “How many wolves does it take to protect the population? Minimum Viable population size as a technology of government in endangered species management (Norway, 1970s-2000s)”, Researchgate.net, page 18, 19, May 2016.
https://www.researchgate.net/publication/299976002_How_Many_Wolves_Does_it_Take_to_Protect_the_Population_Minimum_Viable_Population_Size_as_a_Technology_of_Government_in_Endangered_Species_Management_Norway_1970s-2000s
6. Evans, M. Daniel, et al, “Species Recovery in the United States: Increasing the Effectiveness of the Endangered Species Act”, Ecological Society of America, Winter 2016.
https://www.fs.fed.us/rm/pubs_journals/2016/rmrs_2016_evans_d001.pdf
7. Wild, A. Margaret, et al, “The Role of Predation in Disease Control: A Comparison of Selective and Nonselective Removal on Prion Disease Dynamics in Deer”, Journal of Wildlife Diseases, pages 83-84, 2011.
http://wolfwatcher.org/wp-content/uploads/2015/01/jwd-reprint-Wild-et-al-2011.pdf
8. Beals, Monique, “Feds kill 8 wolf pups from pack tracked for years by Idaho high school students”, The Hill, October 11, 2021.
https://thehill.com/policy/equilibrium-sustainability/576251-feds-kill-eight-wolf-pups-tracked-by-high-schoolers#:~:text%3DA%20wolf%20%22mortality%20list%22%20from,branch%2C%20according%20to%20the%20Post.&text%3DThe%20Post%20reported%20that%20officials%20estimate%20that%20equates%20to%20about%201%2C500%20wolves.
9. “Northern Rocky Mountain Recovery Plan”, U.S. Fish and Wildlife Service with the Northern Rocky Mountain Wolf Recovery Team, August 3, 1987.
https://www.fws.gov/montanafieldoffice/Endangered_Species/Recovery_and_Mgmt_Plans/Northern_Rocky_Mountain_Gray_Wolf_Recovery_Plan.pdf
10. Digest of Federal Resource Laws of Interest to the U.S. Fish and Wildlife Service: Endangered Species Act of 1973.
https://www.fws.gov/laws/lawsdigest/esact.html
Comment Tracking Number
kwu-xwr7-vh10
December 6, 2021
GWA Comments on ESA Wolf Relisting
The comments below were submitted to the Federal Register on the date shown below.
December 5, 2021
U.S. Fish and Wildlife Service:
Concerning Docket No. FWS-HQ-ES-2021-0106
Dear U.S. Fish and Wildlife Service:
Actions by the Trump Administration in October of 2020 have placed the future of wolves in the grasps of wolf proponents and the courts. Anti-wolf advocates have wished to lessen the influence of the species upon the landscape for years. And now, what some believe was a political decision by the previous administration, they have a chance to succeed. The killing of hundreds of wolves in Wisconsin in February of 2021 is one example. Excessive wolf killing is on-going in states of Idaho and Montana. It is obvious to the Gallatin Wildlife Association that these actions are not based upon science, but of hate and stereotypical fears of predators. Now the U.S. Fish and Wildlife Service (USFWS) has taken on the responsibility to review the status of wolves to determine if a policy of relisting needs to be in place.
The Gallatin Wildlife Association (GWA) is urging the USFWS to restore protections to the gray wolf for many reasons, but the most important is to maintain their traditional role as an apex predator, one which contributes balance to the ecology of the wild.
GWA is a local, all volunteer wildlife conservation organization dedicated to the preservation and restoration of wildlife, fisheries, habitat and migration corridors in Southwest Montana and the Greater Yellowstone Ecosystem, using science-based decision making. We are a nonprofit 501(c)(3) organization founded in 1976. GWA recognizes the intense pressures on our wildlife from habitat loss and climate change, and we advocate for science-based management of public lands for diverse public values, including but not limited to hunting and angling.
The Trump Administration argued for the delisting of wolves based upon the fact that recovery numbers had exceeded goals set in 1978. Those goals were established 43 years ago. While the actual meeting of goals is questionable, the subject is really irrelevant. The original 1978 wolf population goals were arbitrary and politically determined. Rationale for those population numbers were not based upon the possibility of a changing science of today nor did it allow for the possibility of a changing landscape, specifically a changing climate resulting in changing migration shifts of prey species.
Trying to find accurate and current population numbers for wolves in the northern Rocky Mountains is as difficult as trying to find a wolf in the wild itself. According to the USFWS1, there are 1,782 wolves in the three states of Wyoming, Idaho and Montana, but those population numbers are based upon 2014 statistics. According to Wildlife Management Institute2, there were a little over 3,100 wolves in the three states of Montana, Idaho and Wyoming during the midwinter of 2020. Yet both of these estimates are far below what the application of the “minimum viable population” (MVP) concept necessitates.
In addition to the MVP concept, the Center for Biological Diversity3 draws this conclusion from their analysis of wolf habitat.
“….we used 27 studies that model wolf habitat in different regions to create a single map. Based on this analysis, there is up to 530,000 square miles of suitable wolf habitat in the United States, only roughly 171,000 square miles of which is occupied, demonstrating that wolves currently occupy only about 30 percent of existing suitable habitat….. According to the studies, these areas are capable of supporting a minimum of 5,000 wolves, which would nearly double the existing wolf population.”
To inform the USFWS on the biological sciences seems analogous to the scenario of a student teaching the teacher, but this seems to be where we’re at in our society today. There have been many studies on the subject of “minimal viable populations”, a concept that is widely practiced and applied in wildlife management to prevent species in the wild from losing genetic viability and going extinct. According to its application, MVP indicates that up to 5,000 wolves could inhabit the northern Rockies of Wyoming, Idaho and Montana. That is double or nearly so based upon the current population trends we know today. While a few wildlife managers may not have complete confidence in MVP applications, they should not be dismissed either.
In a scientific article entitled “Biogeographic and Genetic Factors in Northern Rockies Wolf Populations”, Dr. Ken Fischman4, who holds a PhD in Genetics, states this at the end of his paper.
“Considering all the evidence accumulated, it is clear that the wolf management plans of the federal and state agencies are not based on sound scientific and genetic data or theory. If they are carried out as presently planned, they will undoubtedly lead to genetic impoverishment and possibly to a second extinction of wolves in the Rocky Mountain region.”
Genetics must not be left out of the equation concerning species viability, yet we suspect such discussions were missing from wolf delisting. An interesting read can be found in the research: “How many wolves does it take to protect the population? Minimum Viable population size as a technology of government in endangered species management (Norway, 1970s-2000s)”. According to a scientific paper found on line, Researchgate.net, a paper written by Hakon B. Stokland5 of Norwegian University of Science and Technology, told of an interesting series of events. The story unfolded as a result of the Norwegian government trying to apply MVP to wolves.
This brings us back to the genetics concern. While unintended consequences occurred, such as the measure of viability being revisited in the nation’s court structure, some good science came from that episode which was published in May 2016.
“Biologist at SKANDULV, a project established in 2000 to improve cooperation between Norwegian and Swedish wolf research, saw the difference in estimates of viability revealed in court as highly problematic. In response, they made another attempt to scientifically determine the minimum viable population size of Scandinavian wolves. SKANDULV organized a closed workshop on viability and the Scandinavian wolf population in 2002…..
The panel consisted of international expert biologist: three geneticists, one population biologist, and two wolf ecologists. In addition, Scandinavian biologists, nature managers, and NGO representatives participated…….
The genetic aspects of viability were central to the discussions at this workshop, and the loss of genetic variation in terms of heterozygosity was a topic at the core of these discussions. The geneticists stated that a common criterion for genetic viability was protection of 95-98% of the genetic variation of a population over 100 years, and the panel agreed, in the end, to a definition of genetic viability of protecting, at minimum, 95% of the genetic variation over 100 years. There was some debate over this percentage, in which the ecologists seemed ready to accept a lower percentage (as low as 75 %). The geneticists, however, argued that empirical data from captive populations indicated a critical limit of 95%.”
So, with this in mind, has these determinations been made by the USFWS or other scientists either inside or outside of government for wolf populations in the Northern Rockies or anywhere in the US? Was there even a debate about this issue, a discussion? GWA does not see how a removal of 85% or 90% of the wolves in Montana and Idaho (respectively), as is proposed by these two states, can be done scientifically and/or humanely without jeopardizing the long-term health effect on wolves.
But there is more. Because of climate change, the science of species recovery has changed too. GWA would like to refer the USFWS to the following scientific summary published by the Ecological Society of America. In the Winter 2016 edition, Number 20, entitled “Species Recovery in the United States: Increasing the Effectiveness of the Endangered Species Act”, Evans, M. Daniel6, et al, states this in the opening paragraph of his summary.
“The Endangered Species Act (ESA) has succeeded in shielding hundreds of species from extinction and improving species recovery over time. However, recovery for most species officially protected by the ESA – i.e., listed species—has been harder to achieve than initially envisioned. Threats to species are persistent and pervasive, funding has been insufficient, the distribution of money among listed species is highly uneven, and at least 10 times more species than are actually listed probably qualify for listing. Moreover, many listed species will require ongoing management for the foreseeable future to protect them from persistent threats. Climate change will exacerbate this problem and increase both species risk and management uncertainty, requiring more intensive and controversial management strategies to prevent species from going extinct.”
Hence, the gray wolf needs to be considered in this light since this species is obviously an integral link in the ecology of the wild. Conditions on the ground are forcing scientists to reconsider the recovery goals set so many years ago, believing them to be too low. It is widely known, because of climate change, that species have either shifted or modified their range, some of that due to prey migration. And then you just have the simple effects of drought alone that have placed additional pressures on all species. The Greater Yellowstone Ecosystem (GYE) has been a natural laboratory in the study of wolf impact on the natural landscape. Since their reintroduction of 1995, it is generally agreed that wolves have had an overall positive behavioral effect on elk and on other primary and secondary impacts within the ecological niche of the GYE. And now with Chronic Wasting Disease (CWD), we are learning that wolves by preying upon infected animals can play a more pivotal role in helping to curtail and mitigate the spread of that disease.
There are these quotes from scientific journals. The USFWS should be aware of such research and science in their own behalf, but none-the-less, they are presented here as well. On pages 84 and 85 in the Journal of Wildlife Diseases, Wild, A. Margaret7, et al, in an article entitled “The Role of Predation in Disease Control: A Comparison of Selective and Nonselective Removal on Prion Disease Dynamics in Deer”, there are these statements concerning the role of predation and the disease.
“Alternatively, selective predation by wolves at the same rate would result in a more precipitous drop in CWD prevalence that would culminate in disease elimination in a closed system (Fig. 1E, F). Selective predation does not allow a larger population of susceptible animals to persist relative to the nonselective case because wolves are assumed to consume more susceptible animals as infected ones become rare.
Simulation results suggested that selective predation could also dampen or eliminate the emergence of CWD in new locations (Fig. 3), adding support to speculation that the absence of large predators presents an amplification risk factor for establishment of CWD (Samuel et al., 2003).”
And from the Abstract:
“We suggest that as CWD distribution and wolf range overlap in the future, wolf predation may suppress disease emergence or limit prevalence.”
There are other scientific articles and research that highlights the value that wolves bring to the ecological integrity of our wildlands. And by wildlands, we refer to our forests, grasslands and other biomes home to wolves. The science overwhelmingly shows the critical nature that wolves have on the landscape, but we know that wolves weren’t delisted because of the success of the ESA listing. They were delisted because political actors were wishing it to be so. Political actions have no place in the determination of species viability.
This past year, GWA provided oral and written testimony before Montana State House and Senate Committee hearings over anti-wolf legislation, legislation which quickly became nicknamed “a war on wildlife”. In that legislation, it became obvious those bills were introduced by special interest groups including the trapping industry itself to increase the take on wolves by easing regulations on trapping and to introduce the legalization of snaring. All of the scientific testimony which was presented before legislators at that time was ignored. Likewise, the same could be said about the comments provided to the Montana Fish and Wildlife Commission by those arguing against the implementation and application of the new laws. GWA provided comments in both events and are available upon request.
Such is the regressive and biased political atmosphere in many states across the West. It is this atmosphere that poses a grave danger to wolves and other wildlife species and their habitat. An example of the danger to the viability of wolves can be seen in this story which recently came across our desk. Wildlife Services, a division of the Dept. of Agriculture, recently killed eight (8) wolf pups in Idaho. This story was captured and presented by The Hill magazine dated Oct. 11, 2021 by Monique Beals8. This type of story is not the exception, but is becoming the norm. With this supposedly legal action, how can wolves survive a 90% kill rate of wolves in Idaho and an 85% kill rate in Montana. This places wolves on the precipice of extinction. If wolf pups are allowed to be killed without justification, then there are no guardrails to the slaughter.
In Idaho, Governor Little has already signed into law, legislation that permits the use of night hunting with night-vision equipment, aerial gunning, and hunting from snowmobiles and all-terrain vehicles. In Montana, the story is much the same. Here Governor Gianforte has signed a law extending wolf trapping seasons, authorizing the use of snares and a wolf bounty. These laws also permit the killing of an unlimited number of wolves.
GWA finds all of these actions unscientific and lacking in ethical character, two principles which our organization tries to uphold. We believe this country does not need to institutionalize as a Nation or state, laws that attempt to defend the indefensible. This creates an ecological injustice and violates natural law.
In Summary:
GWA believes that the removal of wolf protections by the previous administration was in itself unlawful in that it violated the intent of the Endangered Species Act of 1973 (ESA). We believe the removal of the wolf from the ESA list was done in order to legalize the taking of wolves for sport or for monetary gain, directly or indirectly. Removal of species protection for personal preference, personal gain, or financial gain of others is wrong and has no place in proper wildlife management of 21st century.
We believe previous actions were wrong as they were not based upon science, ethics or proper wildlife management practices. We also believe that perhaps the ESA was violated, at least the good faith of the ESA, as the law establishes a recovery plan before approval. The latest and only Recovery Plan9 that we have found was signed in 1987, 34 years ago, 33 years before action of wolf removal was approved. The law also requires that there be a five-year monitoring plan for species. Was there any review by USFWS or other appropriate Federal Agencies in this matter based upon the new science and the new conditions on the ground as stated in these comments?
Finally, the ESA states in Public Law 100-478, enacted October 7, 1988, (102 Stat 2306)10, the following provision:
We question whether or not, any of these appropriate steps had been followed in the Trump Administration’s decision in a way that didn’t violate the intent of the law. We find, whether it be state or federal entities, the public’s will has either been ignored or willed inconsequential.
For these additional reasons stated here and for all of the scientific reasoning mentioned above, GWA fully believes the gray wolf needs to be restored and included under protections of the Endangered Species Act of 1973. It is obvious certain segments of our society are incapable of managing wildlife, especially predators in a scientific, rationale, and ethical manner. We have not relieved ourselves of the baggage that has been carried forth by multiple generations. Again, we implore those with the decision-making process, to restore protections to the gray wolf.
Thank you for this opportunity to comment.
Sincerely,
Clinton Nagel, President
Gallatin Wildlife Association
References:
1. U.S. Fish and Wildlife Service website,
https://www.fws.gov/midwest/wolf/aboutwolves/wolfpopus.htm
2. Smith, Chris, “Update on Western Gray Wolves”, Wildlife Management Institute, July 2021 Editin, Volume 75, Issue 7.
https://wildlifemanagement.institute/outdoor-news-bulletin/july-2021/update-western-gray-wolves
3. Weiss, Amaroq, Greenwald, Noah, Bradley, Curt, “Making Room for Wolf Recovery: The Case for Maintaining Endangered Species Act Protections for America’s Wolves”, Center for Biological Diversity, November 2014.
https://www.biologicaldiversity.org/campaigns/gray_wolves/pdfs/Making_Room_for_Recovery_print.pdf
4. Fischman, Ken, PhD, “Biogeographic and Genetic Factors in Northern Rockies Wolf Populations”, April 9, 2008.
http://ancientpathwaystoasustainablefuture.org/1wolves/biogeographic-and-genetic-factors-in-northern-rockies-wolf-populations-2/
5. Stokland, Hakon B., “How many wolves does it take to protect the population? Minimum Viable population size as a technology of government in endangered species management (Norway, 1970s-2000s)”, Researchgate.net, page 18, 19, May 2016.
https://www.researchgate.net/publication/299976002_How_Many_Wolves_Does_it_Take_to_Protect_the_Population_Minimum_Viable_Population_Size_as_a_Technology_of_Government_in_Endangered_Species_Management_Norway_1970s-2000s
6. Evans, M. Daniel, et al, “Species Recovery in the United States: Increasing the Effectiveness of the Endangered Species Act”, Ecological Society of America, Winter 2016.
https://www.fs.fed.us/rm/pubs_journals/2016/rmrs_2016_evans_d001.pdf
7. Wild, A. Margaret, et al, “The Role of Predation in Disease Control: A Comparison of Selective and Nonselective Removal on Prion Disease Dynamics in Deer”, Journal of Wildlife Diseases, pages 83-84, 2011.
http://wolfwatcher.org/wp-content/uploads/2015/01/jwd-reprint-Wild-et-al-2011.pdf
8. Beals, Monique, “Feds kill 8 wolf pups from pack tracked for years by Idaho high school students”, The Hill, October 11, 2021.
https://thehill.com/policy/equilibrium-sustainability/576251-feds-kill-eight-wolf-pups-tracked-by-high-schoolers#:~:text%3DA%20wolf%20%22mortality%20list%22%20from,branch%2C%20according%20to%20the%20Post.&text%3DThe%20Post%20reported%20that%20officials%20estimate%20that%20equates%20to%20about%201%2C500%20wolves.
9. “Northern Rocky Mountain Recovery Plan”, U.S. Fish and Wildlife Service with the Northern Rocky Mountain Wolf Recovery Team, August 3, 1987.
https://www.fws.gov/montanafieldoffice/Endangered_Species/Recovery_and_Mgmt_Plans/Northern_Rocky_Mountain_Gray_Wolf_Recovery_Plan.pdf
10. Digest of Federal Resource Laws of Interest to the U.S. Fish and Wildlife Service: Endangered Species Act of 1973.
https://www.fws.gov/laws/lawsdigest/esact.html
Comment Tracking Number
kwu-xwr7-vh10
December 6, 2021