I must apologize for being slow on this, but on April 23, Ed Bangs, head of the wolf recovery effort in the Northern Rockies (Idaho, Montana, and Wyoming) reevaluated the wolf control regulations that have been effect since 1988 in these states and has recommended revisions. Your comments on his recommendations are due (not postmarked) by May 26. The address is "Wolf Recovery Coordinator, U.S. Fish and Wildlife Service, 100 North Park, Suite 320, Helena, Montana 59604."
I received Bang's evaluation and proposal today. It is a gold mine of information.
In essence, he concludes there has been failure in the ten-year effort of relocation and/or giving livestock-depredating wolves a second chance in NW Montana. Relocated and second chance wolves do continue to kill livestock in the overwhelming number of cases. Therefore, in order to conserve the project's limited resources and "appease" [not his word] livestock interests and their supporters, all depredating wolves in NW Montana should be "removed" [killed] on a prompt basis. Except in unusual circumstances, they will no longer be given a second chance.
In my opinion, Bangs provides substantial evidence that relocation of problem wolves in the area saps personnel and money, and almost all these wolves kill livestock again. Moreover, removal of these wild wolves to humane captive shelters is not feasible because they already have a surfeit of wolves and wolf hybrids. There are other methods besides a straight second change or removal that have not been given sufficient attention. The letter by Defenders of Wildlife (reproduced below) suggests some of these.
The announcement in the Federal Register does not say email comments will be accepeted. Nevertheless, Bang's email is ed_bangs@fws.gov
Below are the comments of Defenders of Wildlife on this proposal. Mine follow after those of Defenders.
May 20, 1998
Mr. Ed Bangs, Wolf Recovery Coordinator
U.S. Fish and Wildlife Service
100 N. Park, Suite 300
Helena, MT 59604Dear Ed,
Please consider the following comments on behalf of Defenders of Wildlife concerning your draft reassessment of the 1988 Interim Wolf Control Plan for the Northern Rocky Mountains.
We would like to start by recognizing that the Service has done an extremely professional job of dealing with the highly controversial and emotional issue of managing problem wolves. We agree that the effectiveness and credibility of the Service's program has significantly improved landowner tolerance for wolves and almost certainly has reduced illegal killing. The Fish and Wildlife Service has done an excellent job in a difficult arena, and deserves commendation for its efforts during this initial phase of wolf establishment.
At the same time, as we enter a second phase of moving toward recovery goals, we are troubled by the high level of wolf mortality that occurred during 1997 in response to depredation incidents. If such levels continue, they may compromise recovery. While we recognize that extraordinary weather may have been a factor, we believe the Service must take a more proactive role in initiating management actions that will move wolf populations to recovery. Should we continue to experience high mortality from control actions, wolf populations could fail to increase or even decline. The Service has a duty to ensure that does not happen.
We are troubled by the proposed "one strike and you're out" policy. At the same time, we recognize that traditional capture and relocation has not been successful (one success in 28 attempts). We are mindful that efforts to give depredating wolves a second chance may consume scarce resources and can lead to needless controversy and conflict. But in order to promote recovery and to maintain strong public support, we feel the Service must devise more creative solutions than just killing all wolves that attack livestock. Our suggestions follow:
1. The Service should identify areas with high wolf recovery potential and initiate acclimation projects in those areas.
Wolf reintroductions in Yellowstone and central Idaho have demonstrated that it is possible to get wolves established in defined areas through holding them in acclimation pens for a period of time prior to release. Defenders believes there are several areas in northwestern Montana that meet the criteria outlined in this document as necessary for sustaining a wolf population (low elevation, abundant white-tailed deer populations, low densities of livestock). Contrary to what is suggested in the document, many of these areas are not currently inhabited by wolf packs. The South Fork of the Flathead and the Swan Valley are two locations that immediately spring to mind.
We believe the Service should designate at least two areas in northwestern Montana during the next two years for experimentation with acclimation and release. While the Service could consider using problem animals for acclimation, a more conservative course would be to take members from an existing pack that has grown large and includes a number of wolves of dispersal age.
It is critical for the Service to experiment with acclimation because similar issues of identifying appropriate areas for recolonization may emerge in both Yellowstone and central Idaho once the core areas (Yellowstone Park and the central Idaho wilderness areas) are completely populated. As your document explains, we understand far better now than we did in 1987 (when the recovery plan was completed) where wolf populations can establish successfully. We need to act on that knowledge. Rather than going through a prolonged trial-and-error process where many wolves die and many landowners become alienated, we should actively attempt to establish wolves in those places where we know conflicts are lowest and chances for success highest.
2. The Service needs more people in the field working with landowners to avoid problems with wolves.
A close look at agency efforts to manage wolf or grizzly livestock depredation in the Northern Rockies reveals one clear truth: The most successful programs, whether state or federal or tribal, have had people on the ground dealing directly with landowners in a consistent fashion. The most obvious example is the excellent grizzly conservation work that Mike Madel, Tim Manley and Dan Carney have done. Similarly, Mike Jimenez' work in the Nine Mile area has made a significant contribution to the acceptance of wolf recovery in an area many people initially believed was completely unsuitable.
The State of Montana has said it will not play the same role in wolf recovery that it has in grizzly recovery. Consequently, the Service needs to design a program that mirrors the State's grizzly management program. Rather than trying to manage wolves from Helena, the Service should hire people to work directly in the field.
3. The Service should initiate field testing of techniques to stop wolves from preying on livestock.
We need options other than killing wolves every time they kill livestock. The best solution would be if wolves could be conditioned not to prey on sheep or cows. If this could be accomplished, they would keep other predators away (since they are territorial) and they potentially would teach their offspring to avoid livestock. Since wolves typically are caught and collared after their first depredation, one technique that could be tried would be to place a shock collar on a wolf that would be activated when it chased livestock. The Denver Wildlife Research Center has conducted successful research with this technique with coyotes using a bell on livestock to trigger the shock collar.
These and other approaches should be carefully evaluated as we look for more publicly-acceptable control mechanisms that reduce the need for killing wolves. Defenders would be willing to assist in sharing the cost of developing such new technologies, and we are certain other groups would be interested as well.
4. To the fullest extent possible, wolf control should focus on individual offending animals.
Experience during the last decade has shown that depredation incidents frequently are linked to a single pack member, and removal of that individual may stem further problems. We believe the Service must be very judicious in any control actions, and only remove entire packs in circumstances where livestock depredation has become a consistent pattern of pack behavior.
Thank you for consideration of these comments.
Sincerely,
Hank Fischer
Northern Rockies Representative
Defenders of Wildlife
Here are my comments on the plan . . . Ralph Maughan
May 23, 1998
Mr. Ed Bangs, Wolf Recovery Coordinator
U.S. Fish and Wildlife Service
100 N. Park, Suite 300
Helena, MT 59604Dear Ed:
Please consider my comments on draft reassessment of the 1988 Interim Wolf Control Plan for the Northern Rocky Mountains.
In general I wish to associate my views with those of Defenders of Wildlife as expressed by Hank Fischer. You and the rest of the folks in the Fish and Wildlife Service, and Carter Niemeyer from Wildlife Services, have put in much time, effort, personal sacrifice, and danger flying for and capturing wolves in the effort to recover the wolf population in the Montana portion of the Northern Rockies wolf recovery area.
The year 1997 saw what is hopefully a just a pause in recovery, as the number of wolves in the Montana area declined and livestock depredations increased. As you indicated this was surely due in part to the effects of the severe winter of 1996-7 on the white-tailed deer population. One would predict that 1998 would see fewer depredations as the result of greater prey survival in the mild winter of 1997-8.
I am not convinced by your argument that almost all of prime wolf habitat is now occupied by wolves, and that, as a result, wolf relocation will almost always be ineffective. I say this even though it is true that there has been just one success in 28 attempts. I cannot believe that NW Montana can support only the approximately 75 to 85 wolves that now inhabit the area. If this is so, how will the recovery goals of ten breeding pairs be met? It should be noted that there are over a thousand wolves in an area of similar size in Minnesota.
Please consider the following:
- Soft release has not been attempted enough. Yes it is true that the movement of the ten Sawtooth pups to Yellowstone was not successful, and they killed more livestock than all of the rest of the reintroduced wolves combined. However, we did learn that taking pups that are totally inexperienced in hunting skills, raising them to yearling status in a pen, and then releasing them does not work. On the other hand, the penning of the adult reintroduced Idaho wolves B7 and B11 has been successful.
The best candidates for this type of soft release are juvenile wolves that know how to hunt, not pups
- The major item in the diet of the Idaho and Yellowstone wolves is not deer, neither white-tailed nor mule. It is elk, just as in the case in the Canadian Rockies in Jasper National Park, Wilmore Wilderness Park, and adjacent areas. Montana has large elk herds, but the wolves are not located in these areas.
May I suggest that you establish enclosures for soft release in areas of large elk herds? One such place is the South Fork of the Flathead River.
In addition the wolves may yet discover new sources of prey. The dispersal of wolves around Yellowstone seems to be stochastic in nature. A good example of this is the fact that the Yellowstone wolves still have not discovered the 18,000 member Jackson Hole elk herd, which largely summers just south of Yellowstone National Park.
- Part of the decline in the number of Montana wolves has come from the movement of two or three packs back into Alberta and British Columbia where there is mostly unoccupied habitat, but this as the result of the high human-caused mortality of wolves in these Canadian areas.
The Service and private groups need to work with Alberta and British Columbia so that the southern portions of these provinces are not sinks for wolves in packs that range across the border.
- Guard dogs do not seem to be effective repelling wolves. However, other types of guards are available. For example, the Wolf Recovery Foundation recently studied the use of wild asses in Texas against sheep and cattle predation by mountain lion and coyotes. The asses bonded with the livestock and were highly effective, not just in protecting the livestock, but in actively pursuing the predators.
- In my opinion, it is false to say that depredation-related wolf removals have not impeded progress toward wolf recovery in the Montana area. Two packs were eliminated in 1997 - the Sawtooth and Browns Meadow. The Boulder Pack persisted due to the timely arrival of wolf B14 from Idaho, but it was eliminated as a pack with a breeding pair. Wolf control, therefore, yielded a minus 3 in the number of reproducing pairs in Montana in 1997. I am not saying that the depredating wolves should not have been controlled. Certainly many efforts were made to salvage the pups in the Boulder Pack. I am just saying the depredation controls, needed or not, have added to the stalling of wolf recovery in the Montana recovery area.
- As Defenders suggests, experimentation with aversive conditioning devices, such as shock collars when the wolves approach livestock, need to be tested.
Many of the things I have suggested cost money. I hope the Service will ask for them from Congress. Undoubtedly the Montana delegation will feel just fine with a one strike policy, but they should learn that no delisting can occur unless the Montana wolf population is recovered.
It is also possible that private organizations can provide you with some of the materials and monies needed.
Thank you for considering my comments, and be sure to inform me of the final changes made to the interim wolf control plan.
Sincerely,
Ralph Maughan, Ph. D
PO Box 8264
Pocatello, ID 83204http://www.poky.srv.net/~jjmrm
Wolf Recovery Foundation
P.O. Box 44236
Boise, ID 83711-0236May 26, 1998
Mr. Ed Bangs, Wolf Recovery Coordinator
U.S. Fish & Wildlife Service
100 N. Park, Suite 300
Helena, MT 59601Dear Ed,
The mission of the Wolf Recovery Foundation (Foundation) is promote wild wolf restoration in the Rockies through advocacy, public education, and direct support of wolf monitoring, protection, and research. The Foundation accomplishes our mission through ongoing public information services, co-sponsorship of the annual interagency wolf conference, raising private funds for radio-collars and aerial telemetry surveys, and matching law enforcement reward funds for information leading to the prosecution of criminals who illegally kill wolves. On behalf of the Foundation, please consider our comments and suggestions concerning your draft reassessment of the 1998 Interim Wolf Control Plan for the Northern Rocky Mountains.
As the Foundation has worked closely with the various agencies and organizations involved in wolf restoration, we wish to recognize the tremendous effort the Service has performed in conducting its role. The Service has faced severe criticism and extreme controversy over the issue of wolf restoration in this region yet has worked collaboratively to ensure both livestock and environmental concerns were addressed - while protecting the primary biological needs of the wolf. We deeply appreciate the Service's leadership and commitment to this project.
Considering there were no known wolf populations in Idaho or Yellowstone merely four years ago, the Service's reintroduction plan has demonstrated obvious biological success. The American public's support for this program has been well rewarded by the outcome. Wolf populations are once again growing in the region. And wolves have demonstrated that they are not a cause of major losses for the livestock industry. Like most predators, wolves kill relatively few cows and sheep compared to thousands of livestock lost to disease, weather, abandonment, and theft. We understand the importance of maintaining good faith relationships with the livestock industry to ensure concerns continue to be addressed and wolf populations are allowed to recover in the least hostile environment possible. Yet, we feel your new proposed "One-strike-and-you're-out" policy will place both wolves and the American public's investment in this program at significant risk and is an unjustified response to the problem. We encourage the Service to examine and implement non-lethal alternatives before resorting to such extreme measures. Our suggestions are as follows:
1. PREDATOR DETERRANTS: The Foundation, through our Wild Wolf Fund partnership, has recently begun studying the use of wild burros in the protection of livestock from predators. Early results appear intriguing. Trained burros bond with domestic herds of cattle, sheep and goats vigorously protecting them from predators. Ranchers using these burros report a dramatic decrease in losses to coyotes and other predators. And burros, unlike dogs, do not need daily care but graze alongside livestock herds making them better suited for public lands grazing. We are investigating the cost of implementation for this program and interviewing ranchers currently using and raising these burros for this purpose. It is possible these burros may offer a solution to lethal control, including the use of M44 poison, in many circumstances. The Foundation will work with the Service to conduct research and develop funding should it be determined this would provide a viable preventative measure to wolf/livestock problems.
2. NEGATIVE CONDITIONING: The Foundation first discussed the possible use of non-lethal shock collars on wolves with Carter Niemeyer, wolf control specialist, several years before the wolf reintroduction program began. The idea was to place mild shock transmitters on the wolves and some kind of repulser unit on the affected livestock. When the wolf approached the vicinity of the livestock, the collar would issue an uncomfortable shock to the wolf, hopefully driving it away from the immediate area. However, it is unknown if the collars would be as effective with wolves or under what conditions these collars would be best suited. If wolves associated the livestock with the shock, these collars may be well worth developing. This rehabilitation alternative should be further examined for cost and long-term effectiveness. The Foundation is highly interested in working with the Service to further evaluate this alternative.
3. PREVENTIVE MEASURES: Many of the wolves that have depredated on livestock have previously suffered injuries such as wounded legs or broken canines which prevented them from successfully hunting wild prey. In areas without domestic livestock, these wolves die as a result of these types of injuries. In regional cases, however, injured wolves have turned to killing livestock instead. Quick lethal control of these wolves is appropriate in these circumstances. However, the Service should work to ensure humans do not cause wolf injuries. Randomly or unchecked leghold traps should not be used in areas near wolf packs. Nor should wolves that sustain human caused accidental injuries, which prevent them from hunting wild prey, be released to the wild.
4. WOLVES IN CAPTIVITY: In regard to placing wolves in captivity, we agree it is usually too stressful for adult wild wolves to be permanently placed in captive facilities. These wolves' lives are reduced to constant trauma and commonly die of stress related injuries. However, many of the wolves that have been involved in livestock depredations have been pups raised and released without the benefit of adult wolves. It is apparent that this method is unsuccessful. On a case by case basis, the Service should consider relocating young pups that lose their parents with other wild wolf packs to determine if these packs will adopt these pups. If this method proves unsuccessful, pups (approximately six months and younger) can be successfully raised in appropriate captive facilities. It is correct that most of the captive facilities in this country are full to capacity nor are they designed to meet the needs of wild born wolves. However, instead of determining that captive placement (short or long term) is not ever an alternative, we ask the Service to view each case separately and flexibly – and to remain open to humane alternatives. We will gladly assist in helping to identify these alternatives when it is not appropriate or possible to place these animals back into the wild.
5.PUBLIC EDUCATION: It is apparent that one of the best, long term tools in maintaining viable wolf populations is public information and education. The Wolf Recovery Foundation has a long history of providing quality regional educational programs in partnership with the agencies involved in wolf restoration. We encourage the Service to step up its educational outreach efforts by developing and supporting strategic planning and implementation of regional educational goals. Again, the Service would have our support and assistance in fulfilling these goals.
It is our belief that these wolves deserve as many options for survival as we can offer them and that the American public would support these efforts over increased killing of wolves. The Foundation is dedicated to aiding the Service and other cooperators with the research, development and funding for these and other efforts to ensure long-term, humane wolf restoration in the region. Thank you for your consideration of these comments and alternative suggestions.
Sincerely,
Suzanne Laverty,
Executive Director
WolfRecovery Foundation
Email addresses for members of Congress other officials, and the media.
Return To Maughan Wolf Report Page
Copyright ©1998 Ralph Maughan
Not to be reprinted, archived, redistributed, etc., without permission.
Ralph Maughan PO Box 8264, Pocatello, ID 83209