February 17, 2006
Attention: Director Steve Huffaker
Idaho Department of Fish and Game
P.O. Box 25
Boise ID 83707
Comments re: IDFG wolf control proposal entitled "Effects of Wolf
Predation on North Central Idaho Elk Populations."
I am writing for the Wolf Recovery Foundation on your proposal to
artificially reduce the wolf population by about 75% and maintain the
wolf population at 25 to 40% of the pre-reduction level for 5 years on
GMU 10 and 12 Lolo Zone in an effort to increase elk populations.
We are not in favor of this, and we believe you provide little to no
data to justify your proposal.
It is admitted in appendix A that most of decline in elk is due to
habitat change – “Perhaps the main reason for the current status of
the elk populations in these GMUs is related to habitat conditions.
The winter range that was created by extensive burns early and in the
middle of the century has deteriorated into overgrown brushfields and
forests. According to recent analysis, there has been a shift in
percentages of early successional stages from historical levels of
35-45% to only 14% today (USFS BHROWS Report 1999). Winter range is
now older and most of it is unavailable for browse because fires have
been actively suppressed for 50 years.”
The primary base of your proposal to reduce wolves is a very small
sample of elk. You collared 64 adult cow elk. We are assuming the
capture and collaring of the elk was random out of the total
population of elk. If not, the sample is nearly useless. We are not
sure if these were collared all at once or over a period of time. It
makes a difference, and the reader should know when they were collared
to see if even this small sample was a one time yet still smaller.
You report in your proposal that “Eight of 25 (35%) mortalities among
adult cow elk from January 2002 through mid-October 2005 were
attributed to wolves. Wolf-caused mortality was not detected during
2002 or 2003; whereas 2 deaths were attributed to wolf predation in
2004, and 6 through 20 October 2005.” “Three additional losses
resulted from resulted from predation, but species of predator could
not be determined. Six cow elk died of unknown causes.”
I am a political scientist who deals with sample surveys to estimate
population parameters for many aspects of voting and public opinion.
We would never make any estimates of population parameters or changes
on the basis of a random sample of only 64 cases. The standard error
of estimate is enormous for such a small sample.
You should continue your study, and increase the sample to perhaps 400
elk. Then reasonable conclusions may be made about how many elk fall
to wolves. Even then it doesn’t tell whether wolf predation is
additional or compensatory. You need to examine the carcasses’ bone
marrow condition and report it. It would be best of the wolves
received GPS collars so that the kills can be examined quickly and the
behavioral patterns of wolf predation determined.
Because talk of reducing wolves and blaming wolves began even as first
pack of wolves appeared, this proposal seems to be in large part a
response to a political demand rather than based on science.
Furthermore, the reduction in elk was predicted long ago as habitat
was seen to be changing.The elk decline began well before wolves were
reintroduced. In the meantime efforts have been made to improve
habitat and kill many other predators, and yet no firm conclusions
about the effects of this have been reached.
You also fail to compare the elk/wolf situation in units 10 and 12
with other elk units in the state that have wolf predation or not, and
yet these data seem to be available. I gathered the following
information from a presentation by Steve Nadeau at a “wolf seminar”
held in Idaho Falls last year.
In zones with "some wolves" 4 showed no
change, 3 were up and none were down.
- In Idaho zones with "many wolves" 3 showed no change in
elk numbers, 2 were up and 3 were down.
You need to compare the zones where elk increased with many wolves
present with those zones with many wolves where elk decreased. Is
there any factor to explain the difference. The factor “wolves” is
being held constant.
- In zones with "no wolves" 3 showed no change, 8 were up, and
3 were down. The no wolf zones were mostly eastern and southern
Finally you conduce a comprehensive survey of elk population every 5
years. If you are to have any hope determining if wolf reduction is
having an effect, you need to conduct a comprehensive elk survey
every year in units 10 and 12. That elk have increased, remained
the same, or decreased after one count five years from now, will tell
us next to nothing about the effects of removing the wolves. Other
factors could be put forward as the cause or causes of the changes
seen in a one shot population count. This is especially true because
you propose to continue to modify other factors that may affect elk
We urge you not to submit this proposal. You need to continue
and expand your monitoring of both elk and wolves in units 10 and 12,
and you need to use these data in a comparative way with other units
that have elk and wolves.
Thank you for considering our comments. Please keep us fully informed.
Ralph Maughan, PhD
Wolf Recovery Foundation
Pocatello, ID 83204
I have also attached these comments in 2 word processing formats.