[To] Mr. Reg. Rothwell, Biological Services Supervisor
Wyoming Game and Fish Department
5400 Bishop Boulevard
Cheyenne, WY 82006

Dear Mr. Rothwell,

Please consider the following comments on behalf of Defenders of Wildlife and its 200,000 members concerning your Draft Wolf Management Proposal. Defenders has been actively involved in wolf restoration efforts in Wyoming for nearly twenty years.

We commend Wyoming's Game and Fish Department for taking the initiative to devise its own wolf management plan. We believe the State's active participation in wolf recovery will increase public understanding about this controversial species, which in turn should translate to improved conservation. Moreover, given the reproductive capacity of wolves and the excellent habitat that's available in Wyoming, we believe that wolf recovery goals can be reached rapidly. It's important for the State of Wyoming to become actively engaged in wolf management now, as it likely will not be too many years before the state reassumes full management responsibility.

BACKGROUND
We are concerned that Wyoming's Draft Wolf Management proposal does not build upon the valuable experience acquired through the wolf recovery process in northwestern Montana, where a wolf population has been recolonizing for nearly fifteen years. In the early 1980s, state and federal managers developed a wolf management plan that constrained wolf recovery to the Glacier National Park/Bob Marshall Wilderness Area. Despite the agency's well-intentioned plans, the wolves recolonized other areas. To the surprise of many wildlife managers, the wolves recolonized most of these new habitats with minimal conflict.

The Montana experience taught us that wolves will roam widely and many establish territories in unpredictable locations. It also taught us that the conflicts caused by wolves are not nearly as significant as many feared they would be. The total market value for all verified livestock losses to wolves in Montana since 1980 is less that $17,000. In every circumstance where wolf depredations have been verified, the wolves have been controlled, the problem corrected, and the livestock producers have been compensated for their losses. This effective system has increased public confidence in the agencies' ability to manage wolves, which in turn has significantly reduced public anxiety over wolf recovery.

Despite fears in Montana that wolf recovery would cause restrictions on the use of public lands, that has not occurred. The only restrictions have been temporary closures of some little-used roads near wolf den sites.

DEFENDERS' RECOMMENDATION

Maintaining credibility with the public is critical to any wildlife restoration effort. Our foremost concern with the preferred alternative is that it makes promises that will be difficult to keep. It proposes to restrict wolves to a relatively small part of western Wyoming that consists primarily of national parks and wilderness areas. It proposes to capture and return wolves that leave the management area.

Capturing wolves is difficult, time-consuming and expensive. It's also unnecessary and wasteful if wolves are not causing problems. The State of Wyoming does not actively seek to constrain the range of any other wildife species; there's no reason to take this approach with wolves. Even at the low numbers we have today, wolves are already occupying habitat outside of the proposed management area. As numbers increase, this will happen more frequently. That will leave the State of Wyoming either spending huge amounts of public funds capturing and relocating non-problem wolves or breaking its promise to the public.

We believe the focus of Wyoming's wolf plan shouldn't be on constraining such a wide-ranging species to an artificially small area. It should be on actively-managing problems wolves wherever they occur. This document presupposes that wolves will cause serious problems, when the best available information suggests they will not. We urge the state of Wyoming to manage wolves the way it manages other large predators like black bears and mountain lions, and not make the wolf a special case. Thank you for the opportunity to comment.

Sincerely,

Hank Fischer
Northern Rockies Representative

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