Wolf Comments Jackson Hole Conservation Alliance
October 9, 2007 Wolf Comments To whom it may concern, Please accept these comments on behalf of the 2,000-plus members of the Jackson Hole Conservation Alliance and the Biodiversity Conservation Alliance regarding the Draft Wyoming Gray Wolf Management Plan (Draft Plan). We view the current Wyoming wolf population as well on its way to becoming a major conservation success story. To ensure that this success isn’t reduced to failure we urge the Wyoming Game and Fish Commission (Commission) to base Wyoming’s Wolf Management Plan on the best available science. As presented, the Draft Plan appears to be dominated by political attitudes and not science. We recognize the legislative constraints the Commission is under in drafting this plan, however, we firmly believe that even with the existing legislation, this plan can be made more responsive to the best available science. We hope that the Commission will work to ensure that Wyoming has a viable, long-term sustainable wolf population. GENERAL COMMENTS: Page 3 of the Introduction states that “Wyoming residents were split in their views” and that 49% of Wyoming residents polled favored reintroduction of wolves to Yellowstone while 39% were opposed. These data are incorrect: Bath (Public Attitudes in Wyoming, Montana and Idaho Toward Wolf Restoration in Yellowstone National Park.1991, p.93) reports 48.5% in favor but only 34.5% opposed. A 14 point difference appears to us to be more than a “split,” which implies something akin to evenness. The same report (p.94) goes on to say “…that most Wyoming residents… support wolf restoration.” If indeed it is the desire of the Commission to use polling data in introducing the Draft Plan, then we urge that the results of the 2003 Wyoming Game and Fish Department’s (Department) state-wide poll also be included (Wyoming Residents’ Attitudes Toward and Opinions on Wolf Management in Wyoming, January 2003). Two conclusions from that poll stand out: First, “[A] majority (54%) of respondents overall strongly or moderately agreed that the 2001 level of wolf predation was acceptable.” Only 33% strongly or moderately disagree that the 2001 level of predation was acceptable (p.16). Second: “[H]alf (50%) of respondents overall either strongly or moderately agreed that wolves are a benefit to Wyoming, while slightly more than a third (36%) of respondents overall disagreed that wolves are a benefit to Wyoming [.]” (p.5). Again, a 14 point difference hardly describes the comment that Wyoming’s citizens are “split” on their feelings toward wolves. The apparent bias within this section of the Draft Plan risks adversely influencing the reader’s conclusions. The Draft Plan provides only a partial review of the existing polling results, incorrectly reports data and makes conclusive statements not justified by the data. The overall effect raises questions about the objectivity of the Draft Plan. Regarding wolf population growth rates: The reader would be led to believe that Wyoming’s wolf population will continue to grow without limits. The Yellowstone National Park (YNP) wolf population growth rate from 1995 to 2000 was between 40-50% per year. The growth rate slowed to 10-15% per year between 2001-2004 (Ten Years of Yellowstone Wolves 1995-2005. p. 18-20. In: Yellowstone Science. 2005. Vol. 13, No. 1). The 2006 YNP wolf population was estimated to be 136, a 15 percent increase from the previous year (Yellowstone Wolf Project. 2006. p.2). The 2006 Rocky Mountain Wolf Recovery Annual Report (p.179) states that the Yellowstone wolf population is expected to decline over the next several years. Providing data from only a few reports, and only one summary from the Greater Yellowstone Ecosystem (GYE) - a summary biased by the growth rates of the first years after reintroduction, which doesn’t mention the most recent trends and predictions - leaves the reader with the erroneous impression that the early growth rates will continue far into the future. The Draft Plan makes no distinction between the growth of the GYE wolf population and the expansion of the population. As presented, the Draft Plan would lead the casual reader to believe that even within core areas such as YNP, the wolf population will continue to increase and not be limited by environmental factors. There is mounting evidence that the YNP portion of the GYE wolf population is stabilizing and that the continued growth in the overall population is a result of expansion into new range, not more wolves occupying the same range. The Draft Plan should focus on the expansion of the wolf population into new habitats: determining where wolves can reasonably be expected to survive with minimal conflicts with human interests and where the presence of wolves will likely lead to unacceptable conflicts with human interests. This discussion should be clearly prefaced with existing data making it clear that even within protected areas, wolf populations will not continue to grow unabated but instead will be limited by environmental factors. Clarifying this point should ward off bias and encourage an objective discussion and a reasoned outcome. Regarding minimum wolf populations: The Draft Plan (p.4) states that “…Wyoming will commit to maintaining 15 breeding pairs and 150 wolves in the northwestern portion of the State including the National Parks and Parkway with 7 of these breeding pairs occupying areas outside the National Parks and Parkway.” A recent and very thorough genetic analysis of YNP’s wolves makes two significant predictions: First, it states that “[A]s expected for an isolated small population of constant size (170), our simulations predict a decrease in genetic heterozygosity and increase in inbreeding coefficient over the next 100 years…For a constant-size isolated population of similar demography and life history, it is predicted that a population size of approximately 600 individuals would be needed to prevent a decrease in heterozygosity and increase in inbreeding coefficients by less than 5% over 100 years.” (vonHolt, B. et.al. The genealogy and genetic viability of reintroduced Yellowstone grey wolves. In: Molecular Ecology. 2007. p.14-16). The results and predictions presented within this study are derived from analyses of 200 YNP wolves and assumes that the Park’s wolf population will stabilize around 170 animals. One goal of the Northern Rockies Gray Wolf Recovery Plan is to establish connectivity between wolf populations in Idaho, Montana (and southern Canada) and northwestern Wyoming in order to facilitate a high degree of genetic heterozygosity. The vonHolt study also predicts that in order to avoid inbreeding and maintain heterozygosity, a minimum of 12 wolves would have to immigrate into the YNP population annually with 4 animals entering the breeding population even with a base population of 600 wolves (p.16). This study determined that between 1995-2004 “[I]mmigration of wolves to YNP from outside the recovery area was not observed or revealed from genetic studies of wolves within or outside the park[.]” (p.6). This would suggest that the current situation is not meeting the goals to maintain long-term heterozygosity and to prevent the problems of inbreeding. Northwest Wyoming’s wolves should be considered as one population including the Parks’ wolves and those outside the Parks. But if the state’s goal is to support only 7 breeding pairs of the required 15 breeding pairs and 150 wolves in total, the loss of heteroxygosity and an increase in the rate of inbreeding seems certain. Consequently, considering that the Parks can support no more than about 160-180 wolves, it is incumbent upon Wyoming to support many hundreds of wolves, perhaps as many as 400-450 to maintain a minimum population of 600. Only in this manner can we provide for the long-term viability of the GYE wolf population. Clearly, maintaining a minimum of 15 breeding pairs and 150 wolves is woefully inadequate and will fall far short of meeting this critical recovery goal and ignores the underlying purpose of the Endangered Species Act (ESA). The ESA is implicit in its recognition of the importance of restoring species and associated ecological processes. Sanja and Berger (Beyond demography and delisting: ecological recovery for Yellowstone’s grizzly bears and wolves. 2003. In: Bio. Cons. 113, p.63-73) make this argument as well as the need to include the degree to which wolves are integrated into their ecosystems as a measure of recovery. They recommend that “…ecological assays should extend as far across recovery zones as possible[.]” in order to determine the concordance between ecological and demographic criteria. The authors are inclined to conclude that wolves have not yet reached their ecological role throughout the recovery zone. We suggest that this may be occurring within portions of YNP where a number of recent scientific and popular articles have told of the increased vigor of various native plant communities in part as a result of elk becoming more mobile since wolves reoccupied the Park. The positive response of some plant communities seems to have influenced both the diversity and abundance of passerine birds and small mammals. Similar hard data and even anecdotal information is lacking for Wyoming outside YNP suggesting that in these areas, the wolves’ full ecological role has not yet been reached. The Draft Plan (p.6) states that “[T]he average size of the 23 packs in Wyoming outside of YNP in 2006 was 6.7 wolves (range 3-13) and 10.5 wolves (range 4-19) for the 13 packs inside YNP.” The Rocky Mountain Wolf Recovery Annual Report for 2006 (p.177, 181) provides information that suggests that the average litter size for YNP wolves and those in Wyoming outside the Park were very similar (6 and 5.7 respectfully). Therefore, it appears that something other than litter size is functioning to control wolf numbers and hence pack size. The answer seems obvious when mortality data is checked. In YNP there were 10 known adult mortalities in 2006 (2 human-caused, 20%) while in Wyoming outside YNP there were 59 known mortalities (57 human-caused, 92%). It appears that human-caused mortality, primarily control actions, are the single most important factor in keeping average pack size smaller in Wyoming than in YNP. Smith et al (Age Structure and Pack Composition of Yellowstone Wolves: Simple and Complex Packs. In Preparation) presents a comprehensive review of wolf pack age structure from heavily exploited populations in Canada and Alaska and compares this to the known age structure of YNP’s unexploited and intensively monitored wolf packs. They state that “[O]lder wolves, especially large male wolves that are on average 20% larger than females, may be particularly susceptible to harvest especially snowmobile or aerial hunting because they are larger, slower and less capable of evading capture…” They go on to present evidence that males have a different role in the hunt than females and are more proficient at killing prey. They make a convincing case that although wolves have a high capacity to replace individuals, packs with primarily younger animals may face a higher risk of being killed by prey or in conflicts with other wolves. They conclude by saying that “…tasks within a wolf pack are mostly shared by older, experienced individuals so harvest may affect wolf behavior and should be considered when wolf control is proposed.” vonHoldt (op cit. p.19) reiterates this concern: “[H]owever, intense control actions in the region (In Wyoming outside YNP) may severely affect the continuity of pack systems and hinder genetic exchange. Moreover, if such actions result in the removal of breeding pairs, this may alter the stability of pack dynamics, leading to higher breeder turnover and more frequent occurrences of inbreeding as mating choices become limited to close relatives.” Although we have no access to data on age composition of Wyoming’s wolf packs, the heavy exploitation they undergo on an annual basis and the comparatively small pack size (6.7 in Wyoming vs. 10.5 for YNP) suggests that the average age of Wyoming’s pack members may be considerably lower than that of YNP’s packs. If so, Wyoming’s packs may have less experience in hunting wild ungulates and defending territories from other wolves than do their Park counterparts. This coupled with the overlap of their territories with the range of domestic cattle may lead to a greater probability of wolves preying on domestic stock, thus putting in motion a cycle of more control and a perpetuation of smaller and younger packs. Therefore, we urge the Commission to do everything within its power to reduce the depredation control action and avoid a public harvest season until the Wyoming segment of the wolf population has stabilized. Fortunately, the Draft Plan commits to providing for a sustainable
wolf population and nothing in HB 213, the Wyoming Legislation guiding
Wyoming’s Wolf Management Plan, prohibits the state from managing
for more than 15 breeding pairs and 150 individuals. We strongly
recommend that the Commission adjust its population goals upward
to accurately reflect the findings and recommendations of the best
available science. Only by doing so can Wyoming’s wolves once
again become self-sustaining components of GYE ecosystems. SPECIFIC COMMENTS: Data Analysis Units: We firmly believe that the primary DAU that now incorporates a portion of the GYE should include the entire Wind River Range and the entire Wyoming Range. This DAU should also include the area between Wyoming Highway 22 and the Snake River, and between US Highway 191 and the Wyoming-Idaho state line. Again, we acknowledge that the Commission is bound to the current DAU by Wyoming Statue, but we encourage the Commission to be an advocate for this change. We make this recommendation because we believe these areas provide excellent wolf habitat and because it would allow for a larger wolf population which would better enable continued genetic diversity and long-term survival of Wyoming’s wolves. In addition, by including the entire Wind River Range in the primary DAU, the Commission would be facilitating the success of the Wind River Indian Reservation’s (WRIR) Wolf Management Plan by providing a means for Wyoming to place protection on WRIR wolves that might have portions of their territories outside the Reservation boundary. Along with the modified DAU, we recommend that the Commission establish three additional DAUs: the first to encompass the area between the GYE and the boundary between Colorado and Utah west of the continental divide (See: Comments, Data Analysis Units, this submission). The second DAU would include the area between the GYE and the eastern edge of the Big Horn Mountains. The last, or fourth DAU would include the remainder of the state. Breeding Pairs: In light of our earlier comments regarding pack size, age structure and its implications for inbreeding and loss of heterozygosity, we urge the Commission to adopt a definition of pack size that respects the best available science, advances the goal of achieving long-term population viability and allows the wolf to assume its historic role in the environment. Only positive information obtained from Department and/or qualified, assigned personnel should be used to determine breeding pairs. Although useful to guide Department personnel in their research and assessment, individual sightings from the public should not be used to determine breeding pairs. Wolf Mortality: All wolf mortalities should be reported to Department personnel within 72 hours regardless of whether it is a legal licensed take, depredation take, defense of private property take or accidental take. This is the required reporting period for mountain lions and it should be adopted for wolves. Allowing up to ten days to report human-caused wolf mortalities is too long and could allow for a significant over kill of wolves. All human-caused mortalities should be counted toward yearly harvest quotas. Genetics and Connectivity: Our thoughts on this subject are included under the General Comments of this submission. Suffice it to say that the information presented within the Draft Plan is woefully outdated and lacking in best available science. Habitat Management: We agree that there should be few if any land use restrictions based solely on the presence of wolves - with one probable exception, that seasonal denning area closures (approximately April 1 to July 1) may be necessary to prevent human disturbances and ensure denning success and breeding pair survival. Nuisance Wolf Management: This heading and the accompanying text leads the casual reader to believe that wolves pose a threat to humans. This attitude is simply not supported by fact and serves only to keep this erroneous perception alive. The phrase and all its implications should be removed from the final wolf management plan. Wolf-livestock Conflicts: We agree with the goal of entering into a Memorandum Of Understanding with the USDA/WS to assist with livestock depredation determination, response and control. We also support efforts to acquire compensation funding and assistance from private and federal sources and we urge the Commission to approach the Wyoming Legislature for appropriations from the general fund to augment such funds. We support the use of State General Funds because wolves do generate income to the region in the order of millions of dollars per year and much of that is taxed and goes into the general fund (See: Comments. Economic Impacts, this submission). Other Wolf-Human Conflicts: We urge the Commission in its Final Wolf Management Plan to eliminate the phrase “Human-Wolf Conflicts” and replace it with “Other Wolf-Human Impacts.” We strongly support the Commission in its efforts to include the wolf into its “don’t feed the wildlife” campaign. Habituation of any large mammal to human food sources can only lead to problems that usually result in expensive control actions and too often end with the death of the habituated animal. Management Actions: We offer a qualified agreement with the procedures outlined for management actions. We would like to see a distinction between individual’s ability to take wolves that are damaging property or attacking livestock based upon whether it is occurring on private land or public land. Situations occurring on public land should undergo far more scrutiny than those occurring on private land. Predator/Prey Interactions: Reading this section reminds me more of a political than biological presentation - it is so one-sided and biased that it nearly defies response. Completely lacking is any information on recent research coming from YNP research staff. A thorough response to this section on wolf/ungulate interactions is not necessary at this time. Suffice it to say that only in very rare cases do wolves exert such an impact on ungulate populations as to warrant significant wolf control. We know of no Wyoming elk population in existing wolf range that is “in trouble.” We are aware of no peer-reviewed studies that support the claims or implied conclusions presented in the Draft Plan. None. Wolf management plans based upon insinuations and speculation are not “best available science” decisions. The discussion on moose population trends in Jackson Hole is extremely biased. The moose population began its decline in the 1980s, long before 1997, the time the first wolves appeared in Jackson Hole. Recently completed studies indicated that factors other than predation account for more than 60 percent of female moose deaths. Predation by bears accounted for about 14 percent while only 2 percent of recorded moose deaths were attributed to wolf predation. Preliminary indications from an ongoing (Univ. Wyo-WG&F) moose study in Jackson Hole suggest that the moose decline may have halted and that the population may be increasing, in spite of 4 wolf packs occupying the moose range. The primary cause of the decline appears to be associated with poor habitat impacting both pregnancy rates and calf survival rates. To focus on predation as the cause of moose decline is highly biased, unprofessional and disingenuous. (Citations are available upon request.) The discussion on wolf/elk interactions is so one-sided and misleading as to be embarrassing. The discussion about elk calf:cow ratios is misleading in that it picks only certain years to make points. For example, the report states “[T]he 2003 calf:cow ratios for both the Gros Ventre feedgrounds and the NER decreased for the second consecutive year (Table 2)[.]” (p.24). It fails to mention that the same Table 2 indicates that the ratio increased in 2005 and 2006 on the NER and increased in 2006 in the Gros Ventre area. Statements such as: “[T]hus, the decline in calf:cow ratios in both areas indicates that while wolf predation likely played a role in the decrease of the Gros Ventre feedground ratios, factors such as other predators and the prolonged regional drought also were influential.” There is no data presented to support a direct cause and effect relationship between wolves and the alleged decline in the calf:cow ratio. Even with the tacit acknowledgement that drought and other predators may play a factor in this ratio, the reader is left with feeling that wolves remain the leading culprit. Again, there is no peer-reviewed analysis to support these insinuations. The discussion of wolf interactions on elk winter feedgrounds fails in the most basic sense because it doesn’t acknowledge that Department-maintained winter feedgrounds are akin to providing an “attractive nuisance” for elk, and thus for wolves. With the attitude presented in the Draft Plan, wolf presence is taken as a potential or real problem that triggers actions to be taken against wolves. If wolves are to exist in Wyoming, and this point is not open to debate, wolves will be attracted to feedgrounds, that is where the elk are. The consequences of this kind of interaction should be anticipated, it is natural. What is unnatural is the annual, artificial concentration of hundreds of elk on very limited areas. Management actions, if any need be taken, should first deal with eliminating the “attractive nuisance” of baiting and concentrating elk onto feedgrounds. If, for whatever reason, elk become a nuisance to private property, management actions should include protecting the property with elk-proof fencing. To focus management actions solely on wolves is a set-up to eliminate wolves. The past history of immediately removing wolf-killed elk carcasses from the vicinity of feedgrounds must not reoccur. Removing carcasses deprives the wolves of feeding opportunities and forces them to kill again, probably much sooner than if they were allowed to completely consume the carcass. Similarly, examination or handling of elk carcasses by Department staff should not occur until after the carcass is mostly consumed so as to avoid the chance of carcass abandonment leading to extra predation. The Draft Plan lists every conceivable inconvenience attributed to wolves coming to elk feedgrounds. It provides the number of feedground elk killed by wolves but makes no attempt to differentiate between additive and compensatory mortality. Page 24 of the Draft Plan states that “[W]hile there has been a significant wolf presence on the Gros Ventre feedgrounds in recent years…” and “Wolf presence was documented on 14 of the Department’s 22 elk feedgrounds during the winter of 2001-2002 and on 12 feedgrounds in the winter of 2002-2003.” But no information is provided to define what constitutes “significant wolf presence” or if the 14 and 12 feedgrounds visited was done so by single animals or packs, and what was the outcome of the “visits.” On page 25 it states that crowding (caused by wolves driving elk from one feedground to another) aggravates the risk of brucellosis transmission among elk. Yet there is no accompanying data - nor do we believe that any exists - that would make the case that wolf presence has in any way increased the brucellosis infection rate among elk. Making unsubstantiated claims, suggesting or making conclusions not supported with data and using inflammatory words is unprofessional, eliminates objectivity and disgraces the core principles of the scientific process. Our greatest concern is the manner in which the alleged wolf/elk feedground conflicts will be resolved. The recovery goal identifies the State as having to maintain a minimum of 7 breeding pairs and the National Parks as maintaining 8 breeding pairs. Perhaps the 8 packs assigned to the Parks can be maintained within Yellowstone National Park. However, two Jackson-area packs have traditionally denned within the boundaries of Grand Teton National Park and another incorporates a portion of the Park within its territory. The fourth pack dens within the National Elk Refuge and includes portions of the Park, the Refuge and the surrounding Bridger-Teton National Forest in its territory. Currently at least 3 of these packs come in contact with one or more of the three Gros Ventre feedgrounds during any given winter. If control actions are taken against any of these packs because of their visiting the feedgrounds, it could directly impact Park and/or Refuge wolves. And if any or all of these packs were eliminated or reduced to such a level as to no longer be able to defend their territories, the one pack now least likely to visit the Gros Ventre area will likely move in that direction as it offers better wintering habitat. If this happens, it too could be controlled and even eliminated. These scenarios need to be addressed with the consultation of resources managers from the three federal land management entities, and need to incorporate the best available science. Doing anything less is not responsible wildlife management and certainly not responsible management of a species about to be removed from ESA protection. Clearly, wolf control actions in the Gros Ventre Valley have the very real potential of reducing or eliminating packs now inhabiting at least parts of a National Park and a National Wildlife Refuge. These are unacceptable outcomes. Big Game Management: Although Wyoming has a very laudable history of managing wildlife at or above herd objectives, it does so at a cost. For elk in particular, part of that cost is the tradition of winter elk feedgrounds which are now the most important factor influencing the high prevalence of brucellosis in northwestern Wyoming’s elk herds. It is estimated that the infected elk herds suffer a 6-8 percent drop in calf production due to abortions brought about by the impact of Brucella abortus, an organism not native to North America (As reported in: Smith, B. 2001 “Winter Feeding on Elk in Western North America.” J. Wldf. Mng. 65(2):173-190.) We simply ask how a potential 6-8 percent increase in calf production would relate to the number of elk taken by a stable wolf population. We believe that the increase in calf production resulting from the eradication of brucellosis would be equal to or greater than the overall loss due to wolves. Since elk feedgrounds are the major factor contributing to the high brucellosis infection rate, and because the feedgrounds are a cause of concern to the Commission, perhaps the future of feedgrounds should also be included in the long-term management plan for wolves. We are very disappointed with the tone of the discussion concerning big game management. It focuses entirely upon the single goal of producing as many individuals of a few desired species, such as elk, moose, mule deer and big horn sheep, and paints the wolf as being, or as about to become, the major obstacle to achieving this goal. The Draft Plan simplifies the natural interactions of habitat, climate, disease, big game and predators to the point where wolves appear to be the major impediment to successful wildlife management in northwestern Wyoming. The Draft Plan goes to great lengths to report wolf kill rates on various big game species but makes no attempt to discuss the nature of the predation. What portion of the depredation was additive and what portion was compensatory? Were they old or young? Injured or diseased? What was the condition of the herds in question? Were they over objective or under? What impact did the depredation have on the herd size, age structure and overall longevity? To simply provide kill rates without providing additional details or a complete discussion of the various situations surrounding the big game species prejudices the reader’s impression of wolf/prey interactions (See: Comments, Predator/Prey Interactions, this submission). Public Information & Education: We agree with the Commission that a balanced Public Information and Education campaign will be crucial to successful management of wolves in Wyoming. However, the plan as outlined in the Draft Plan is completely lacking in presenting an accurate review of the best available science surrounding the role of wolves in the environment. A crucial part of a successful I & E program must include all the best available information and not focus, as the Draft Plan does, on just big game depredation rates. For example, a successful campaign must include the secondary and indirect consequences of having an established and stable wolf population in northwestern Wyoming. It must also present conclusions based upon a complete analysis of all factors involved in the study results and it must provide an unbiased analysis of the implications. Funding: We strongly support the Commission in their efforts to obtain other sources of funding as long as they remain free of requirements to initiate management programs not supported by sound ecosystems management policies and best available science. We suggest that the Commission begin this process by requesting financial support from the Wyoming Legislature to assist with the burden of managing species that are of benefit to the entire state such as the wolf and grizzly bear. We particularly believe it appropriate that state funds be used to compensate for verified wolf depredations upon private property. We urge the Commission to work with Wyoming’s Congressional Delegation to obtain appropriated federal funds to support the management of wolves (and grizzly bears) and to eventually assist in establishing a trust fund whose dividends are available to Wyoming, Montana and Idaho for the management of wolves and grizzly bears. As we have stated publicly, if the citizens of the United States consider the survival of these species to be important - and all the polls we are familiar with conclude such - then all the citizens of this country should share in the costs of maintaining these species. These costs cannot be born by this state alone and certainly not by the Wyoming Game and Fish Department alone. A cost associated with Wyoming’s successful game management programs is the direct dependency upon revenues derived from selling big game licenses. This direct connection understandably drives wildlife managers and the Commission to take every reasonable action to provide for as many big game animals as the habitat can support. The Commission must find a way to free itself from its nearly sole dependency upon license revenue. Only then can it begin to free its management programs from the need to provide a maximum number of big game animals in order to accommodate license sales sufficient to operate the Department. As we break this dependency, we can more objectively appreciate the value of having wolves in northwestern Wyoming. Economic Impacts: The Draft Plan’s discussion of economic impacts is so incomplete, one-sided and biased as to defy description. Regarding wildlife, the report only provides costs associated with loss of big game animals and subsequent loss of license sales revenue. It completely ignores revenues generated by the wolf viewing public and simply dismisses this factor by stating that “…overall visitation to Yellowstone National Park has decreased for unknown reasons since wolf reintroduction[.]” (p.31). The Draft Plan also dismisses any revenue generated by wolf views as not generating “…income for wolf management by the Department[.]” (p.31-32). And yet the Draft Plan makes estimates of the financial loss to cattle producers, even though those costs are not now compensated for by the Department. A recent economics analysis of the revenue generated directly by
visitors going to YNP to view wolves concluded that in 2005 more
than 35 million dollars were spent in gateway communities (As reported
in: “UM economist: Wolves a big moneymaker,” Mike Stark.
Billings Gazette. 04-07-06.) A soon-to-be-released report (Yellowstone
Science: In press) estimates that when the roll-over factor is calculated,
the value of wolves to the surrounding communities approaches 85
million dollars annually. We recognize that these funds do not directly
enter the Department’s coffers, consequently, we reiterate
our recommendation that the Commission request funds from the State
General Fund and from the Federal Government for the management of
Wyoming’s wolves. (See: Comments, Funding, in this submission.) Summary: We thank the Wyoming Game and Fish Commission for the opportunity to submit these comments regarding the Draft Gray Wolf Management Plan. We conclude with the following summary comments: 1. The Commission should work with the Wyoming State Legislature to do away with the dual classification for wolves and adopt a single Trophy Game Area encompassing all of Wyoming (excluding Yellowstone and Grand Teton National parks, the National Elk Refuge and the Rockefeller Memorial Parkway). 2. We strongly recommend that the Commission adjust its population goals upward to accurately reflect the findings and recommendations of the best available science. 3. The primary Data Analysis Unit should be expanded to include all of the Wind River Mountain Range, the entire Wyoming Range and the lands between Wyo. Highway 22 and the Snake River along US Highway 89, and the Idaho border and US Highway 191/89. Three additional DAUs should be described as outlined in the body of this submission. 4. Wyoming’s wolves should be managed like other wildlife species, at carrying capacity and not as an arbitrary lower level barely sufficient to meet USFWS recovery goals. 5. Long-term management directives should be based on conclusions reached by analyzing best available science. 6. Every reasonable effort should be made to ensure that wolf travel corridors remain open for the free movement of wolves between the Greater Yellowstone Ecosystem population and those in Montana and Idaho, and for the eventual dispersal of wolves from Wyoming into Colorado and Utah. 7. Agency control efforts and hunter harvest levels should be limited so as to inflict minimal impact to wolf packs, their age structure and size. 8. All human wolf-caused mortalities should be reported the Department within 72 hours. 9. Supplemental funding for the long-term management of Wyoming’s wolves should be sought from the State Legislature, the Federal Government and private sources, and a trust fund should be established whose proceeds could be used by Wyoming, Idaho and Montana for the management of both wolves and grizzly bears. 10. The Commission should establish and support a comprehensive Public Information and Education program that will provide the most current information on wolf biology and the wolf’s role in the environment. Respectfully submitted, Franz J. Camenzind, Ph.D. Duane Short |