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.

He said
In Idaho zones with "many wolves" 3 showed no change in elk numbers, 2 were up and 3 were down.
              In zones with "some wolves" 4 showed no change, 3 were up and none were down.
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 Idaho.
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.

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 populations.

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
Box 444
Pocatello, ID 83204

I have also attached these comments in 2 word processing formats.