Was just emailed a copy of this from RMEF:
Washington Dept. of Fish and Wildlife
Attn: Phil Anderson, Director
600 Capitol Way N
Olympia, WA 98501-1091
The Rocky Mountain Elk Foundation (RMEF) has had the opportunity to review the previous version and now the Final Environmental Impact Statement for the Wolf Conservation and Management Plan for Washington along with the minority group comments and the three blind peer reviews. We also took advantage of attending the public meeting of the Commission in Ellensburg on August 29, 2011.
Writing a management plan for a species that has not been present on the landscape for a very long time is a challenge. Few of us have any personal knowledge or experience with wolf management and must learn from those who have experience. The RMEF has learned a lot from the wolf restoration efforts in Idaho, Montana and Wyoming. The 1995 experimental population project was new to everyone as there were no wolf experts in any of these state wildlife agencies. Many of the unknowns at the time have become known’s and should be used as important lessons learned.
Under your proposed plan, the goal of 15 breeding pairs may be difficult to achieve and maintain across the three recovery regions proposed. In 1994, when the wolf restoration project was approved for Idaho, Montana and Wyoming, the initial population goal was 10 breeding pairs or 100 wolves in each of the three states. Once wolves were released and set up territories, most agreed to increase the number to 15 breeding pairs or 150 wolves in each state. The primary reason for this buffer was that there were no adjacent wolf sources in nearby states or provinces at that time. Washington is in a different situation with existing healthy wolf populations in Idaho, Alberta and British Columbia. We believe a lower goal for Washington Department of Fish and Wildlife (WDFW) would allow management to occur earlier in the project and still maintain a viable wolf population with good genetic variability.
Elk are the primary prey species for wolves in Idaho, Montana and Wyoming. The elk population in the three states in 1995 was estimated to be 311,840 elk (Idaho – 116,000; Montana – 93,401; Wyoming – 102,439). A subset of these totals is the elk population for the Greater Yellowstone Ecosystem (GYE) of 124,000 elk. The 2010 post season Washington elk population estimate from your department is 61,250 (Rocky Mountain subspecies – 22,000 and Roosevelt subspecies – 39,250). This seems like a lot of elk in Washington today but similar thoughts existed about the Yellowstone elk in 1994.
The actual elk count (not population estimate) of the Northern Yellowstone herd in Montana was 19,045 in 1994, the year before wolves were reintroduced. The 2011 post season count was 4,635 elk. Wolves were added to areas with healthy grizzly bear, black bear and mountain lion populations. It is important to note wolves were not solely responsible for the decline, but certainly have made a significant contribution to the predation side of the equation. Many of those contributing factors are also at work in Washington today. To put this example in context, the number of Rocky Mountain elk in Washington today is just slightly larger than the Northern Yellowstone herd population prior to wolf reintroduction. Similar declines in Washington elk herds are unacceptable to hunter conservationists and RMEF.
Wolf populations in Montana, Idaho and Wyoming have increased and expanded over a larger area than predicted. Genetic diversity has remained high due to the dispersal of yearling and two-year-old pups to occupy new territories and establish new packs. Experts at the time (pre-1995) had similar concerns about minimum number of wolves as did two of the three blind peer reviews that accompanied this plan. None of the experts in the GYE or Central Idaho anticipated the population growth or extensive distribution of wolves that has taken place.
While it was interesting to learn the model estimated that Washington has a similar amount of wolf habitat as Idaho and Montana, we would submit that wild prey (primarily elk) numbers and/or densities will dictate the habitat used by wolves. There is little likelihood that wolves will try to occupy a habitat without an adequate wild prey base, but will likely move to another area or switch to domestic livestock as a prey base.
Roosevelt elk populations have been a concern for some time now with agencies, conservation groups, hunters and other conservationists. Calf recruitment has been very low in many of their populations due primarily to a lack of early-seral and mid-seral successional forage openings caused by a lack of disturbance (either natural or man-caused). It is no secret that Roosevelt elk thrived during the heavy forest disturbance caused by logging that occurred prior to the old growth (Spotted Owl) issue that resulted in the Northwest Forest Plan of 1999. Much of the logging/forest thinning activity was eliminated and Roosevelt elk have had a difficult time since.
Elk calf survival in the Blue Mountains has been a concern for a number of years and has been actively researched, primarily by Oregon Dept. of Fish and Wildlife, U.S. Forest Service, Boise Cascade Timber Co. and RMEF. The concern precedes the arrival of wolves dispersing into the area from Idaho. Washington and Oregon are not the only areas outside of wolf occupied habitat that are having calf survival challenges. Similar concerns have been identified in South Dakota where research is underway. There are no wolves, grizzly bears, and very limited black bear populations in the Black Hills. The point is that elk do have some challenges across the west and the addition of wolves will increase those challenges.
The Absaroka Elk Ecology study conducted by the University of Wyoming and others in the Cody, Wyoming and Yellowstone National Park area has found that in addition to wolf, grizzly bear, black bear and mountain lion predation, another factor is limiting calf recruitment. Study results determined that changes in weather patterns and moisture over the past decade seem to have reduced the “green-up” time for elk forage plants on summer range causing a measured reduction in nutritional quality. This has resulted in a reduced pregnancy rate in elk.
RMEF strongly encourages a statewide recovery wolf population goal rather than designating the three identified wolf recovery regions. The GYE and Central Idaho projects did not distinguish specific areas as wolf restoration or management areas. This allowed project managers the most flexibility in this project where most managers had little or no previous experience with wolves. These area boundaries are human attempts at predicting where wolves will distribute themselves or where planners are hoping the wolves will take up residence. Wolves will make that determination and their choices can often be quite different from predictions.
Defining three specific recovery areas could prevent flexible management required to address the dynamic changes that can occur with wolf restoration. The current management plan precludes assisted migration until criteria for delisting to threatened or sensitive status are met. That could lead to many more wolf packs in the eastern zone than is required to delist while the other areas are well under that level. That could easily lead to higher than expected impact on elk, moose, deer and bighorn sheep as well as numerous situations of wolves preying on domestic livestock. Under the proposed plan this would limit action by the agency to address the situation. We recommend that you build as much management flexibility into the plan as possible to allow for unforeseen situations.
RMEF strongly recommends eliminating the three year waiting period after the wolf population has reached the delisting criteria before the wolf management plan can be implemented. GYE and Central Idaho met the delisting criteria in 2002 and delisting was not recommended by the U.S. Fish and Wildlife Service until 2008, a time period that allowed wolf numbers to increase by as much as 34% each year resulting in a population nearly five times higher than the delisting criteria goal. This complicated the wolf management plans of Idaho and Montana. A wolf hunt was held in Idaho and Montana in 2009 and then lawsuits prevailed to re-list the wolf population under the Endangered Species Act (ESA). The U.S. Fish and Wildlife Service met the due diligence required by the lawsuit and again recommended delisting. The criteria were all met but delisting still did not occur under the ESA. Instead, it took Congressional action to remove the wolf from listed category status in Idaho, Montana and portions of Washington, Oregon and Utah. There is no reason to believe that federal delisting in the remaining part of Washington will happen any sooner nor will lifting the state endangered species classification be a simple matter. We recommend that a wolf population management plan be in place and implemented as soon as the delisting criteria are met. Waiting an additional three years will only complicate management of wolves, ungulates and livestock depredation. If the plan can be quickly and smoothly transitioned into place and a wolf hunt plan and other control methods are in place, the agency will have the best opportunity to effectively manage the wolf population.
The state of Washington has a large human population, viable elk populations and a livestock industry. Wolves will be here for certain and their management will be a challenge. To maintain healthy wolf populations requires healthy wild ungulate populations. It is important to recognize the investment that hunters have made to conservation through purchase of hunting licenses, fund raising and volunteer conservation projects. Their investment has helped provide abundant big game populations and the plan needs to ensure that the opportunity to hunt big game will be balanced with the needs of wolves.
RMEF strongly believes that wolves and other wildlife within the state boundary are best managed by the Washington Dept. of Fish and Wildlife, not the federal government or state and federal courts. We do hope you will take advantage of the lessons learned in Montana, Idaho and Wyoming since 1994. As always, RMEF stands ready to assist WDFW for the sake of all wildlife.
Sincerely,
M. David Allen
President & CEO
Rocky Mountain Elk Foundation
