Wolf Recovery Foundation opposes heli-darting wolves
in the Frank Church Wilderness.12-30-2005, three additions 1-4-2006, addition 1-8
The Wolf Recovery Foundation has sent comments to the Intermountain Region of the U.S. Forest Service opposing a plan by Idaho Fish and Game to use helicopters to dart and then land to radio collar wolves inside the Frank Church Wilderness. Our opposition is not based on radio-collaring, but on use of motorized equipment inside a designated Wilderness area, of which the Frank Church is the largest in the lower 48 states.
Convenience for administrators is not the intent of the Wilderness Act, and in fact radio collaring of wolves is proceeding pretty well in Idaho as a whole, without use of helicopters not to mention Wilderness. Note that this is much more of a wilderness issue for most folks than it is an issue about how wolves are detected and managed. Designated Wilderness areas are very special places to many folks, and while a dozen or so wintertime landings in the Frank have little environmental impact, this idea enlarged to the entire wilderness system is horrible to think of. So it has to be nipped in the bud.
If anyone else wants to comment you have until January 4, 2006 to email your comments to:
comments-intermtn-regional-office@fs.fed.us
Our comments follow.
December 30, 2005
Mr. Randy Welsh, Regional Wilderness Specialist
USDA Forest Service Region 4
324 25th St.
Ogden, UT 84401
RE: Scoping Notice for Motorized Use Authorization in Frank Church Wilderness for Idaho Fish and Game, Wolf Collaring
Dear Mr. Welsh,
Here are the comments of the Wolf Recovery Foundation on the scoping notice you issued about the request of Idaho Fish and Game to use motorized equipment (landing of helicopters) to collar undocumented wolves in the Frank Church Wilderness.
We did not receive the scoping notice from you. You were probably not aware of our interest, but we want to be contacted about any future similar proposals in designated Wilderness areas of Region 4.
The State of Idaho has promised the US Fish and Wildlife Service that they will maintain a minimum of 15 breeding pairs of wolves in Idaho. Idaho Fish and Game is, as you indicate, interested in counting wolves and investigating wolf behavior. This is very important, and wolf populations must be documented each year. We want to stress that wolf collaring is, therefore, a routine matter, meaning it must be done every year.
Darting wolves from the air every year and landing helicopters every year in a place legally dedicated to non-motorized use (Wilderness) is a major intrusion. It is a major imposition on the Wilderness Act. You have chosen to handle this major change of use with a very small categorical exclusion of only 3 pages.
This is not legally sufficient. The results of your scoping should show that you need to do a full environmental analysis. Your scoping notice was hardly publicized at all, and we would have missed it had others not been vigilant.
Your office might protest that Idaho Fish and Game needs approval by early January 2006 to perform the heli-darting. That would be correct for this year. Failure to approve would mean that they cannot do this is in January 2006. However, Idaho Fish and Game has already met their legal responsibility for 2005, and it is highly likely they will easily met it for 2006.
So far in 2005, 36 breeding pairs of wolves have been identified in Idaho, more than twice the number required!
Moreover, 3 packs (breeding pairs) have been discovered inside the Frank Church this year (Golden Creek, Monumental Creek, and the Hoodoo Pack), proving that wolves can be documented without heli-darting.
You dismissed alternative B in your scoping document, but alternative B is already a proven success.
We must remind you that the Wilderness Act was not created to provide for the most efficient or the most technologically advanced method of managing natural resources. Just the opposite is true. Your scoping document does not seem to recognize this essential element of the purpose of the Wilderness Act -- use of primitive technology.
You dismiss Alternative B, "Use leghold traps to capture gray wolves." You state that it is less successful, takes longer, and is more likely to injure wolves.
It does take longer to do it by trapping, but except for 3-4 wolf collars deployed in the state of Idaho in 2005, all collaring this year was accomplished by means of leghold traps. If trapping works in non-wilderness backcountry, it will work in the Frank Church. Two of the three packs identified in the Frank Church in 2005 were identified after leghold trapping.
Your indication that trapping is more likely to injure wolves is not documented. Traditional traps used by fur trappers are not used, and wolves are seldom injured seriously by trapping for radio collaring. On the other hand, a number of wolves have been killed by aerial darting in the three state 10j wolf recovery area.
You fail to mention that trapping wolves creates employment opportunities for trappers and perpetuates the knowledge of important, traditional outdoor skills.
Therefore, we conclude,
1. This is a controversial action. We believe you have received many comments contesting your proposal, including some from people who have actually managed wolves.
2. This an introduction of a new and continuing motorized use incompatible with designated wilderness areas.
3. Idaho wolf population counts in the past, both inside and outside the Frank Church Wilderness, have been done without aerial means.
4. Much research on the wolves of the Frank Church Wilderness has already been done, especially by Jim and Holly Akenson, without helicopters.
5. Efficiency is not a relevant concern in a designated wilderness area.
6. Alternative B works and is compatible with the Wilderness Act. Your proposal, alternative A, is not compatible with the Wilderness Act.
We are firmly opposed to this proposal. Regardless of our support or opposition, this proposal requires far more than a scoping for a categorical exclusion.
We think if the matter is taken to court, a judge would issue a summary judgment against your proposal.
Sincerely,
Ralph Maughan
President, Wolf Recovery Foundation
PO Box 444
Pocatello, Idaho 83204
1-4-2006. The Western Watersheds Project has sent in some interesting comments. See WWP comments.
Second addition 1-4. I talked with Steve Nadeau, Large Carnivore Program Coordinator for Idaho Fish and Game about the proposal. Big game winter counts take place every three to five years, not annually. The idea is to dart and land a biologist or two to radio collar any wolves they come access inside the Frank Church. It is not a project they expect to repeat annually, or necessarily repeat at all. As a result, it may not be as precedent setting as it appears. One thing is for sure, The US Forest Service did an awful job informing people, requesting public comments, and allaying fears.
Note that Nadeau will now replace Carter Niemeyer of USFWS in making the day to day management calls on Idaho wolves. Day to day wolf management is now essentially in the hands of the Idaho Department of Fish and Game.
Third addition. The story has gone regional. Idaho wants permission to use helicopters to track wolves [in the Frank Church Wilderness]. Jan. 4, 2006. By John Miller. AP. Seattle Post-Intelligencer.
1-8-2006. I don't know if USFS Region 4 regional forester Jack Troyer quickly signed off on this as the public comment period ended, but I have heard estimates that from 300 to 700 responses (many detailed letters) were sent once the public got wind of the matter. Come next week, we will see if this was a flash-in-the-pan controversy or whether a lawsuit is filed.
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Ralph Maughan PO Box 8264, Pocatello, ID 83209.
Wolf Recovery Foundation; PO Box 444, Pocatello, ID 83204