Here is the language from the "Minority Group" letter to Harriet Allen opposing the Washington Wolf Plan:
http://graywolfnews.com/pdf/Final+Wolf+Comments+6-13-11+Minority+Group.pdfTo: Harriet Allen, Endangered and Threatened Species Manager
Date: June 23, 2011
From: Minority Group
RE: Minority Group Comments on WDFW Draft Wolf Plan
These comments are presented on behalf of the Minority Group. By definition the DRAFT Wolf Plan is supposed to be a Draft Conservation and Management Plan for Washington. It is written like a recovery document for an ESA species such as the Desert Tortoise not an apex predator like the Wolf. As most recovery plans do not consider long term management objectives this document does not either. However when dealing with an apex predator like the wolf it is essential to have the support of impacted stakeholders and the only way to achieve this is by discussing long term management plans. The WDFW could have attempted in the Wolf Working Group process to address concerns and effects of the Plan by both sides if they would have allowed a discussion on management objectives instead of focusing on the number of Breeding Pairs (BP’s) to delist. In order for the Wolf Working Group, WDFW Commission and the public to fully understand the effects of this plan long term they must consider the following:
Sec #1.
Projection of Wolf numbers based upon the DRAFT Plan.
A. The Wolf Plan on page 62 line 10 states that 15 BPs = “210 total wolves or 14 wolves per BP or an average of 30 packs”.
B. Using data from the NRM on page 71 of the wolf plan it only took “ID 7 years to go from 14 to 251 wolves and WY 9 years to go from 21 to 234 wolves”. Therefore Washington with approximately 30 wolves today should be at 210 wolves in 8 years.
C. With 15 BPs, (210 individual wolves), This is an example of what the wolf population could look like in 11 years (210*1.24*1.24*1.24 = 400 wolves)(Federal Register/Vol. 74, No. 62/ Thursday, April 2, 2009/Rules & Regulations page 15166 average population growth of wolves in the NRM (24%/yr) per Federal Register).
D. Then the state will need to conduct the SEPA/NEPA process for de-listing which would take a year or more and thus another 24% growth resulting in 496 wolves according to page 62 of the wolf plan this would mean there were as many as 71 different packs this is what the wolf population could look like in 12 years.
E. This is what would happen if the delisting process was held up for 2 years with litigation 496*1.24=620 wolves 620*1.24=775 wolves. This is what Washington could look like in 14 years.
One solution, eliminate the 3 year waiting period, go with immediate de-listing at the target number (this process will take a year) with ability to re-list if population falls below the de-listing target. The elimination of the 3 year waiting period would only take a WAC change from the Commission. There is no Federal requirement for a 3 year waiting period with 15 Breeding Pairs. Immediate de-listing would result in a population of 262 wolves instead of 496 when delisted without a lawsuit.
Sec. # 2.
In order to understand the impacts of Wolf populations on Ungulates in Washington State you must consider the following:
A. Page 94 line 33, “In some areas and situations, wolves select adult bull elk disproportionately”.
In Game Management Units (GMUs) within the Clockum and Blue Mountain Herds, hunters have gone to spike only seasons to preserve the large bull elk for breeding and to maintain the bull to cow ratios. There is a very limited draw for tags, raffle tags and Governor’s tags for branch antler bulls that generates the WDFW $200,000+ per year. In these GMUs most of the mature bull elk winter by themselves or in groups at fairly high altitudes and in deep snow not with the cows and young bulls in the lowlands. These bulls will be the first animals taken by the wolf in winter and will dramatically affect the management goals as to bull to cow ratios plus revenue.
B. See page 113 lines 10-18 of Wolf Plan – projected number of deer and elk killed annually by wolf populations. The chart from page 113 for “300 wolves used a low 2,550 elk, average 3,165 elk and high 3,780 elk for annual kill rates by wolves”. We utilized the average or 10.55 elk killed/ year/wolf as per the WDFW Draft Wolf Plan. The available NRM science shows figures of 11-30 elk killed/year/wolf plus deer kill. Using the average from above of 10.55 elk/killed/wolf/year (or the lowest number possible) should eliminate the arguments that this number is cumulative. The same logic has been applied to deer kill.
C. Current Hunter Harvest including Olympic Peninsula (Elk) 7,390 (pg 180 ln 16-36)
D. Current Hunter Harvest including Olympic Peninsula (Deer) 40,375 (pg 180 ln 16-36)
D. Deer kill by 300 wolves 5,250/yr. ave
E. If the delisting process is held up for 2 years with litigation 496*1.24=620 wolves 620*1.24=775 wolves (see Sec 1 sub E of this document).
F. In 1992 the NRM reached its de-listing target number. It took 19 years of litigation and an Act of Congress to de-list.
G.
see chart: Sec 3.
“At Risk ungulate populations” see preferred alternative. “If the WDFW determines that Wolf predation is a limiting factor for “at risk ungulate populations” and the population within that recovery region is healthy it could consider moving of wolves, lethal control or other control techniques in localized areas. The definition of a healthy wolf population is one that exceeds recovery objectives and that management objectives would not push the population below those objectives and put it at risk”.
A. Sportsman and the WDFW have invested a large amount of dollars into the introduction and recovery of various at risk ungulate species
B. There is a considerable amount of revenue generated into the WDFW to support “at risk species” on an annual basis.
Wolves depredating on “at risk species” should be removed or killed regardless of listing status. If this action results in a reduction in BP’s it is still much cheaper to re-locate a breeding pair within that recovery region but not back into the at risk ungulate habitat, rather than sustaining losses to the ungulates.
Sec 4.
In the Preferred Alternative under Ungulate Management “the WDFW is going to manage for healthy ungulate populations through habitat improvement, harvest management and reduction of illegal hunting consistent with game management plans. Harvest objectives may need to be adjusted if overall predation levels increase. Harvest level need to be compatible with long-term sustainable populations of predators and prey”.
With the plan lacking a targeted maximum population on wolf numbers the WDFW is sending a clear message that they intend to adjust hunter harvest levels to provide for wolf consumption first and hunters second. We believe that if WDFW intends to have a sustainable wolf plan then they must conduct a Population Viability Analysis on prey species by Game Management Areas and include hunter harvest and wolf harvest.
Sec 5.
The plan adds a statement in chapter 12 task 5.4 “that the ecological roles of predators and prey should be integrated into game management plans for ungulate and carnivore species”. Does this mean the WDFW intends to manage ungulates and carnivores with Sigmoid Curves? If the WDFW intends to manage on the ecological roles and not manage on Sigmoid Curves there must be a targeted maximum population of predators in the WDFW Game Management Plans. Does the WDFW intend to include or exclude hunter harvest, if so at what level?
Sec. #6.
Wolf Control – See page 71.
The bottom line is that USFWS/USDA “killed 1,517 problem wolves themselves in order to recover 1,614 wolves in the ID, MT, WY (NRM)”. This recovery was 3.5 times the updated listing of 450 wolves for these three states. This did not include wolves killed illegally or on highways etc.
A. Currently the Wolf Plan does not convey a will to kill problem wolves at a rate of 10-25% annually. (see page 71 wolf plan).
B. The WDFW stated to the Wolf Working Group throughout the 3+ years the Group met that the WDFW would use lethal take to address livestock depredations by wolves. However, the WDFW Draft Wolf Plan established additional criteria that will be very difficult to meet. „They suggested that lethal control be limited to solitary individuals or territorial pairs whenever possible, and that removals from reproductive packs should not occur until pups are more than six months old, the packs contain six or more members (including three or more adults or yearlings), neighboring packs exist nearby, and the population totals 75 or more wolves. Consideration should also be given to minimizing lethal control around or between any core recovery areas that are identified, especially during the denning and pup rearing periods (April to September) (E. Bangs, pers. comm.)(page 136 lines 32-39)”.
C. The WDFW Commission has not begun discussions around authorization of lethal take on wolves in Washington and as a result this is not a tool that is available in the foreseeable future. The Wolf Plan states “that in establishing the limitations and conditions related to wolves, the Commission “shall take into consideration the recommendations of the Washington state wolf conservation and management plan.””(page 86 lines 40-42). The Director has the authority to adopt emergency Rules. Has the Director made the decision to authorize lethal take of wolves that have depredated upon livestock or at risk ungulate species or will the Commission decide?
D. Ensuring that Animal Welfare is protected has always been a top priority amongst livestock producers and pet owners. Livestock producers and pet owners are very concerned that the establishment of wolves in their area will negatively impact their livestock/pet welfare. As livestock producers and pet owners it is very difficult to see animals that have been attacked by wolves and have suffered horrific injuries. Our traditional belief is that it is our duty and obligation as stewards to our livestock and pets to prevent such attacks from occurring in the first place instead of simply relying upon “compensation” for wolf related losses. It is unconscionable to us to simply stand by and allow such trauma to be inflicted upon defenseless livestock and pets.
Problem wolves should be killed not “moved or translocated”. All problem wolves need to be killed in order to prevent against social intolerance of wolves. This plan will never be successful without Management +Control=Social Tolerance
Sec 7 #
Habitat
A. Washington’s Population of 6,724,540 people and a population density of 100.5 people/sq mi. This is 6 to 18 times the human population density of the 3 principle states in the NRM area, MT, ID, and WY. (WA, WY, ID, and MT state web sites). According to the Federal Register, Feb.8, 2007, Vol.72, “number 26 Washington State has only 297 square miles of suitable wolf habitat in the eastern third of the state” (p.6117 Federal Register). This same report indicates that if the 3 major states (ID, MT, and WY) “can support 10 BP’s for 3 years that the species can be considered to be fully recovered and can be considered for delisting” (p.6107 Federal Register). That criteria was met in 2002 (p.6111 Federal Register).
B. The Carroll model determined that 28% of the NRM DPS could be ranked as suitable wolf habitat (p.6117, Federal Register). On the same page they also stated “We believe that the Carroll ( et al. 2006 pg 31-34) model tended to be more liberal in identifying suitable wolf habitat than either the Oakleaf ( et al 2006 pp 558-560) model or our field observations indicate is realistic, but Carroll’s model provided a valuable relative measure across the western United States upon which comparisons could be made.”
C. The Oakleaf model indicates that 65,725 sq. mi. (p6117, Federal Register) or 19.8% of the states of WY, MT, and ID is suitable habitat. We also believe that the habitat modeling done by the WDFW, that finds a larger percentage of WA, the smallest, in land area, of the western states with more than twice the population of the states of MT, WY, and ID to be flawed at best or intentional at worst.
D. On page 52 of Alterative 2 of the Draft Wolf Conservation and Management Plan for Washington, the WDFW using the Carroll model shows a high of 41,500 sq. mi. or 61% of the state, to a low of 16,900 sq. mi. or 23% of the state as suitable habitat. The USFWS as previously mentioned using the same Carroll model could only find 297 sq. mi. of suitable habitat in the eastern third of the state. This report didn’t cover the western two thirds.
E. Furthermore, WDFW on the same page using the Oakleaf model compiled by Dr. Maletzke found that the state had 26,700 sq. mi. of suitable wolf habitat or 40% of the state. This compares with 19.8% that Oakleaf found to be suitable habitat in WY, MT, and ID. This discrepancy could be due to the fact that Dr. Maletzke (pg. 49) only used “four parameters ( i.e. prey density, forest cover, human density, and presence of sheep allotments) to determine suitable habitat”. Oakleaf ( pg.6117, Federal Register) “used roads accessible to two-wheeled and four-wheeled vehicles, topography ( slope and elevation), land ownership, relative ungulate density ( based on state harvest statistics), cattle ( Bos sp) and sheep density, vegetation characteristics (eco region and land cover), and human density…”.
F. Also WDFW used Larsen and Ripple to determine suitable habitat. We honestly don’t know where the Department found these folks. A Google search indicated that their area of expertise was populations of Aspens in the Yellowstone area and to a lesser degree the indirect effect of wolves on the growth pattern of these trees.
We don’t want to think that the discrepancies between the modeling work done by the WDFW and USFWS are due to the WDFW’s desire to justify a larger population of wolves than the state can support, but it appears this may be the case especially in view of the fact that the latest version of the WDFW Wolf Plan reads more as a justification for the recovery of wolves than a conservation and management plan.
Sec. #8
Prey availability
A. Page 99 lines 44-46, “Elk are a highly valued resource in Washington. Ten major herds are recognized in the state (Figure 13) and range in size from estimates of 900 to over 13,000 animals (Table 11). These total over 57,000 animals statewide, of which about 59% occur west of the Cascade crest”.
B. Page 101 line 5, “The total state population of elk is 57,865; The Northwest Coast has an elk population of 16,220” leaving a population of 41,645 in the Eastern Region, Northern Cascades and Southern Cascades.
C. The elk population in the Eastern Region, Northern Cascades and Southern Cascades (wolf zones 1,2&3) is 41,645 elk, Idaho’s elk population is 100,000, Montana’s elk population is 117,880 and Wyoming’s elk population is 120,000
It is inconceivable considering the vast differences in habitat, prey availability and human population between Washington and the NRM that we (Washington State) should have 15 BP’s + 3 years to de-list when the NRM was required to only have 10 BP’s per state plus 3 years to de-list but arbitrarily agreed to 15 BP’s with no waiting period per state to de-list.
The USFWS has found that the 3 major states in the NRM can maintain a viable population of Wolves with 10 BP. Common sense would dictate that Washington would be able to do then same. The states within the NRM have proven that they can maintain a healthy population over a 3 year period, there is no reason that we couldn't do the same. Therefore, we insist that the WDFW eliminate the 3 year waiting period. Also, if Wolves were delisted at 10 BP to a Big Game status the WDFW could begin to derive income off of the species by offering limited Hunting. We would agree with 10 BPs as long as there was a targeted maximum population not to exceed 200 wolves and the major items within this document are addressed.
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