Idaho Fish and Game P.O. Box 25 Boise, ID 83707 idfginfo@idfg.idaho.gov Attn:
Wolf Plan Comment December 27, 2007 To Whom It May Concern: The following
comment is submitted on behalf of Friends of the Clearwater with regard to
the proposed Wolf Management Plan 2008-2012. Because of the deficiencies
discussed below, this plan should not be implemented. Rather, further
research should be conducted and meaningful public comments should be
solicited. 1. The public commentary used to draft, support and develop the
Wolf Management Plan is insufficient and biased. Bottom Line: Because the
majority of those polled were hunters and/or heads of households and because
the data collected is presented without any context, we cannot support
IDFG’s reliance on such biased data. While we commend IDFG on its attempt
to proactively compile public opinion by conducting a survey of various
groups within the Idaho population, we have the following comments regarding
the data that was collected. a. The questionnaires collected by Idaho Fish
and Game (IDFG) surveyed an unrepresentative population and thus represent
biased data. Additionally, the questions themselves only provide useful
information if viewed in light of assumptions about information the
interviewees may have had. The questionnaires used by IDFG failed to offer
any meaningful data. While the questions might have yielded valuable
information had they been answered by a representative population, those
polled were generally of the same demographic. Additionally, the questions
themselves only provide valuable information when viewed in relation to the
data that was available to those who answered the questions. In light of
these complications, a heavy reliance on this data is misplaced. i. The
majority of the population polled were hunters. From the data provided by
IDFG one might assume that the majority of Idaho’s population consider
themselves hunters. This is far from the truth. In fact, according to a USFWS
survey of 2006 data, issued in July 2007, wildlife watchers far outnumber
hunters in the state. Additionally, it has been documented through declining
license sales that the percentage of hunters in Idaho has declined in the
past ten years. This declining population has essentially been counted twice
in IDFG’s survey. IDFG specifically polled hunters as a discrete group,
then proceeded to randomly poll the public. However, because of the list they
chose to use as their random cross-section, a majority of those randomly
chosen were also hunters. By surveying two populations comprised of
essentially the same individuals and then adding them together when
calculating percentages, IDFG skews the results of its own survey and
prevents meaningful conclusions. ii. Heads of households comprised the
randomly selected public. Additionally, IDFG itself identifies a bias within
its survey. Proposal, pg. 38. The list of randomly selected individuals was
comprised of those who were heads of the household. IDFG acknowledges that
this list ended up consisting of primarily older males with land lines and
stable addresses. While IDFG recognizes the bias within the survey, it does
nothing beyond an acknowledgment. In fact, it continues to use the data as if
the bias presents no significant threat to the viability of its computations.
iii. The data to which the public had access when answering the survey
provides essential context to the analysis of the data compiled by IDFG.
Without this context, the numbers are essentially meaningless. Without a
clear understanding of what information the public used in answering IDFG’s
survey, the answers given lack an essential context. If the public is
ill-informed, the responses received by IDFG simply reflect this unfortunate
circumstance. When the public concurs with a policy simply because they lack
education on the issue, their concurrence does not provide truly meaningful
feedback. While we in no way assert that this is the case here, IDFG provides
no context that would conclusively prove the value of the questionnaire one
way or the other. As such, this data is really only of limited value. iv.
Conclusion Because the data provided by the IDFG survey is both bias and
contextually complex, it is imperative that IDFG reconsider the weight it
gives to this data. If IDFG wishes to rely upon this data, further inquiry
and recalculation are both necessary. IDFG can gather viable data by taking
three steps. First, a wider population should be queried, a population
comprised of more than the “heads of households.” Second, hunters should
not be counted in two discrete categories. Finally, IDFG should provide some
context in which the numbers can be interpreted. The context should include
but not necessarily be limited to the information to which the public had
access when answering the questionnaire. If these steps are taken, IDFG will
have data that more accurately reflects the opinions of Idaho's entire
population. b. Holding a comment period during the holidays threatens the
public’s ability to submit meaningful commentary and thus jeopardizes the
spirit with which comment is sought. Holding a public notice and comment
period between Thanksgiving and New Year’s Eve runs contrary to the spirit
with which the IDAPA was enacted. The idea behind public notice and comment
was to give the public a chance to offer meaningful commentary. Holding a
comment period during the peak holiday season likely silences voices that
would otherwise participate in this discussion. If the IDFG and USFWS truly
wanted a discussion with the public about how to most appropriately deal with
increasing wolf populations following their potential delisting, the notice
and comment period should be scheduled inclusively, not exclusively. 2. No
accurate measurements of wolf mortality are available. The USFWS admits that
it likely underestimates the levels of wolf mortality. Bottom Line: Because
the proposed wolf management plan is not based on accurate data regarding
wolf populations and their respective health, the wolf management plan is
based upon insufficient and/or irrelevant scientific data. Currently, no
accurate measure of wolf mortality exists. Proposal, pg. 7. Neither a
mechanism nor a process exists by which IDFG can accurately measure the
levels or causes of wolf mortality. Because not all of the wolves in Idaho
wear radio collars, IDFG has been unable to accurately measure the levels of
wolf mortality. Additionally, IDFG has no mechanism with which to measure
levels of infant mortality. As such, IDFG readily admits that its estimates
of wolf mortality are not accurate. Indeed, IDFG acknowledges that its
estimates tend to underestimate the actual level of wolf mortality. In light
of IDFG’s lack of accurate data on wolf mortality, it seems hasty and
ill-informed to proceed with a management plan of any kind before studies
have been developed and pursued in the hopes of achieving more accurate and
comprehensive data. Common sense dictates a comprehensive understanding prior
to effective species management. While accurate data might lead IDFG to its
current conclusion, its absence leaves a vacuum from which a successful
management plan cannot arise. Consequently, we cannot support a management
plan that fails to consider comprehensive and accurate information. 3. The
ecological effects of wolf predation are generally positive. Bottom Line: In
light of the many positive effects wolf predation can have on entire
ecosystems, artificial control of their populations should be approached with
great care. The IDFG’s proposed wolf control plan does not approach its
mission with sufficient care. Wolf predation keeps ungulate populations at
healthy levels and helps promote the ecological well-being of native regions.
The results of studies conducted within Yellowstone indicate that wolf
predation has produced several positive ecological effects. Proposal, pg. 14.
First, the decline in elk populations and their increased unwillingness to
graze in willow groves has led to the rejuvenation of the willows within
Yellowstone. Second, the carcasses of elk killed by wolves provides
sustenance to other carnivores and scavengers, suggesting an increase in the
fitness of species, such as “grizzly bears (Ursus arctos), red and grey
foxes (Vulpes vulpes and Urocyon cinereoargenteus), common ravens (Corvus
corax), and bald and golden eagles (Haliaeetus leucocephalus and Aquila
chrysaetos) (Smith et al. 2003).” Proposal, pg. 14. Based on this
information, it seems unnecessarily risky to institute a wolf management
program that is based upon insufficient data. 4. Using prey species as a
measurement for the health of the predator populations is superficial,
inappropriate and self-limiting. Bottom line: Because the only measurements
used in crafting the Wolf Management Plan arose from prey populations, its
success seems improbable. Consequently, we cannot support its implementation.
Unlike similar predators, wolves within the state of Idaho are not monitored
as a distinct and independent species group. The health of both bear and
mountain lion populations are individually monitored. The health of wolf
populations, on the other hand, is monitored according to the health of prey
populations, namely elk. Not only does IDFG fail to independently monitor
wolf populations, but when they consider the health of elk populations, they
attribute all fluctuations to wolves, or predation. To dismiss habitat
issues, poor management decisions, human predation, weather conditions, and
human encroachment and simply lay the blame on a predator is not sound
science. Overall, this approach to wolf management attempts to simplify
complex and interrelated ecological and habitat issues. As discussed above,
the effects of wolf predation on ecosystems is complex and varied. Basing
measurements solely on prey data suggests that the proposed plan is a wolf
control plan as opposed to a wolf management plan. Were the interest truly in
effective wolf management, it seems likely that IDFG would attempt to obtain
scientifically viable and appropriately balanced data. To make a simplistic
deduction, that all elk problems may be solved by predator reduction (wolves
in particular) shows a lack of understanding of or data about natural cycles
in predator prey relationships and to a living ever evolving ecosystem. 5.
The effect wolf predation has on elk populations has been mischaracterized
and misrepresented. Bottom line: A great deal of conflicting data regarding
the health of elk populations in Idaho requires a holistic approach to
interpreting the data. Any piece of data taken in isolation can be
misleading. As such it is an oversimplification to use isolated data to
suggest that wolf predation has significantly decreased elk populations. In
Idaho, elk populations across the state have held at or near all time highs.
IDFG Project W-170-R-30, Elk Surveys and Inventories, 7/1/05 - 6/30/06. As
most of the concern within the State of Idaho at this time centers around
hunting Region 2, and more specifically to four hunting zones comprising of
ten individual hunting units the need to highlight this area in relation to a
reason for this wolf culling proposal is paramount. The continued practice of
managing elk for revenue has caused many of Idaho's problems in the
aforementioned hunting region. To begin, an ecosystem cannot be managed for a
single species. The notion that elk and only elk should dictate management of
a wildland ecosystem is an archaic premise no longer favored by sound
science. Using IDFG data as far back as 1988, one can find a historical
fluctuation in elk numbers within Region 2. These natural peaks and valleys
occurred long before any substantial wolf population ever existed. Using the
most current data from IDFG (Clearwater Region Sightability Estimates,
Updated 2/26/07, Clay Hickey, IDFG) there are clearly areas where elk numbers
across the board have increased even with a growing wolf population. It has
been documented that the average age of cow elk that wolves take is 12.6 and
that of hunter harvest is 7.3. It can be viewed that the loss of cow elk to
wolves is compensatory where loss to hunter harvest is additive. It also
raises the question as to which predator (two legged or four legged) is doing
more damage, and which, should manipulation occur, have a greater impact on
elk numbers. Since 1998 - Selway zone, hunter numbers and harvest have
steadily increased. In the Elk City zone, hunter numbers have remained steady
with an increase in harvest and in the Dworshak and Lolo zones hunter numbers
and harvest have remained steady and or increased respectively. IDFG, Project
W-170-R-30, Elk Surveys and Inventories July 1, 2005 - June 30, 2006. If
wolves were deleteriously affecting elk herds, it seems unlikely that elk
populations would continue to increase in every zone in Region 2. IDFG
conducted a study (Project 160-R-33, July 1, 2005 - June 30, 2006, Zager)
concerning predator manipulation (increased predator harvest) in several
zones in Region 2 to assess elk calf mortality. Over a period of seven years,
manipulation of black bear and mountain lion harvest were tried in several
units across two zones. The results of the manipulation failed to elucidate a
method for assessing the long-term increase in elk population as well as calf
to cow ratios. Results from different zones contradicted each other in both
calf mortality and the general population. Unit 16 A in the Selway Zone
between 1991 and 1995 (no wolf population at that time) had a decrease in
calf/cow ratio from 32.2 to 14.7. Conversely, without any predator
manipulation, and a growing wolf population present, the calf/cow ratio
increased during the period of 2000 to 2004 from 14.7 to 28.5. The ratio has
dropped again 28.5 to 16.1 in what seems to be a normal cycle for this area.
Clearwater Region Sightability Estimates, Updated 2/26/07, Clay Hickey, IDFG.
In Unit 20 from 1992 to 1996, there was a drop in calf/cow ratio from 33.7 to
15.2 with no wolves present (Zager, 2006). Between 1997 and 2007 with wolves
present calf/cow ratios have increased from 15.2 to 27.1 Clearwater Region
Sightability Estimates, Updated 2/26/07, Clay Hickey, IDFG. Elk numbers in
the Salmon zone were at all time highs that prompted an increase in cow
harvest across the zone while a healthy wolf population existed. (IDF&G
Project W-170-R-30, Elk Surveys and Inventories, 7/1/05 - 6/30/06) If wolves
are catalyst to depress and decimate elk numbers what is taking place in the
Salmon Zone that refutes this premise? IDF&G acknowledges that weed
infestation, reduced logging and a lack of fire (natural or prescribed) have
caused the habitat to become less than stellar for elk and in fact has shown
to be a problem for calf survival. Project 160-R-33, July 1, 2005 - June 30,
2006, Leege and Hickey. These examples illustrate how complicated a
relationship predator and prey have with their respective ecosystems. Clearly
any of this data in isolation could lead one to any number of conclusions. It
is only when all the data is viewed holistically that a clear picture of
predator, prey and ecosystem interaction emerges. To simplify wolf
management, to consider only elk data when crafting such a management plan,
does a disservice to the wolf population, to the ecosystem as a whole and to
the people of Idaho. We strongly recommend that IDFG take into consideration
data similar to that used in bear and lion assessments before finalizing its
wolf management plan. 6. Culling wolf populations may adversely affect wolf
populations. Bottom line: Because wolves are social animals and because so
little data has been collected with regard to wolf populations independent of
their prey, we strongly urge IDFG to conduct appropriate studies prior to an
attempt to cull wolf populations. Wolves are social animals that travel and
thrive in packs. While natural selection usually eliminates weak, sick or
elderly animals, human predation can often result in the death of the strong
young wolves that simply lack the experience to avoid human contact. This
approach to wolf management removes strong reproductively viable individuals
from the pack on a continuing basis. There is not sufficient data to allow
IDFG to fully understand what impact such loss will have on wolf populations
and how much loss a population can sustain before it creates an irreversible
imbalance. While it is likely that the wolf population can sustain some
degree of such loss, the lack of data regarding wolf mortality in general
creates a significant risk that the impact could far exceed untested
hypotheses. In light of this lack of data, it is imperative that IDFG conduct
studies that assess wolf, rather than elk, populations and that this data is
sufficient to produce statistically significant results. As such, we cannot
support the implementation of IDFG’s wolf control plan without
significantly more data. 7. Allowing “wolf control” to perpetuate large
elk herds for the sole use of hunters is an attempt to privatize a public
resource. Bottom line: In order to satisfy its duty to the American public to
protect wildlife, IDFG must put the welfare of wildlife and ecosystems ahead
of economic gain and hunter interests. As George Wuerthner astutely pointed
out in his recent comment, wildlife is considered a public resource within
the United States. George Wuerthner, Guest Opinion: Killing Wolves Violates
Public Trust, pg. 1. As such, entire wildlife populations cannot be
appropriated solely for private gain. Wuerthner suggests that “to shoot
wolves merely to increase the number of elk or deer so state wildlife tag
selling agencies can privatize these animals by selling hunting licenses to
hunters to kill ungulates is a violation of this public trust obligation. Of
course, this pattern is part of a larger problem whereby state wildlife
agencies typically ignore the needs of non-huntable wildlife species. It is
also symptomatic of a world view that seeks to manage for production, and
treats nature as it were a factory that can and should produce an even flow
of goods‚ in this case elk or deer to be consumed.” George Wuerthner,
Guest Opinion: Killing Wolves Violates Public Trust, pg. 1. Agencies charged
with the administration of wildlife management and protection of wildlife
have a duty to the American public to carry out this duty with the best
available data and with the utmost respect for the public resources. In order
to achieve this goal, IDFG, must set aside the potential economic benefits
and political pressures in favor of sound scientific management. IDFG can
certainly consider hunter concerns and economic gains when crafting a
wildlife management plan, but these considerations may not be tantamount to
the management of public resources for the public’s benefit. IDFG owes a
duty to the American public to make management of public resources paramount
to all other concerns when creating resource management plans. 8. The plan
does not address the issue of wilderness and the positive mandate that
federal land managers have in protecting wilderness character which includes
natural functioning of wildlife populations. While the Wilderness Act
recognizes a role of states in wildlife management in wilderness ( section
4(d)(7)), this does not override the positive mandate of the US Forest
Service (or the Bureau of Land Management, which has jurisdiction of a very
small portion of the Frank Church-River of No Return Wilderness) to preserve
wilderness character. The statutory intent of the wording in the Wilderness
Act has been repeatedly upheld by the courts. Furthermore, the supremacy
clause in the US Constitution gives ultimate authority over wildlife and fish
on public lands to the federal government. Several cases have referred to the
U.S.C.A., Article IV Sec. 3, clause 2 rulings under U.S. Constitutional law.
Gere v. Connecticut in the late 1800s notes states have wildlife jurisdiction
only to the extent it doesn't interfere with federal authority. Cases which
have upheld the supremacy of the federal government to manage wildlife by way
of the authority granted in various federal statutes include Hunt v. U.S.
(278 US 96) U.S. v. State of Washington (520 F.2d 676) New Mexico State Game
Commission v. Udall (410 F.2d 1197) and Kleppe v. New Mexico 426 US 529. In
the latter case the U.S. Supreme Court ruled that "We hold today that the
property clause gives Congress the power to protect wildlife on the public
lands, state law notwithstanding." As such, the plan needs to explicitly
recognize the role of predators in designated wilderness and the positive
mandate given to the federal land management agencies to preserve wilderness
character. For example, the Forest Service Manual (FSM) notes in, 2323.33c
that, Predacious mammals and birds play a critical role in maintaining the
integrity of natural ecosystems. The FSM clearly gives the Forest Service
jurisdiction to deny or approve predator control but only allows approval
under very narrow parameters, none of which include building big game
populations. Any wildlife research or management conducted by the IDFG must
also meet sections 4b and 4c of the Wilderness Act which precludes, among
others, structures, installations, and the use of motorized vehicles. Only
the land management agency, and then only under two very narrow
circumstances, is granted exceptions. One is in case of an emergency
involving people within the area and the other is only when necessary to meet
minimum requirements for the administration of the area as wilderness. As
such, the plan must be explicit in recognizing designated wilderness as
source populations where wolves are allowed to play their ecological role.
The same should also apply to the unroaded backcountry on public land owned
by all Americans. Conclusion We cannot support the IDFG Wolf Management Plan
2008-2012. This plan is an oversimplified approach based on inconclusive,
biased data. Additionally, this plan could very likely have severe and
adverse effects on the health of Idaho’s wolf populations. We must say that
we are a bit shocked at IDFG’s response to the potential delisting of
wolves from the Endangered Species List - that the moment wolves attained
populations high enough to be delisted, the first thing the IDFG did was to
begin to plan significant culling. According to IDFG’s own staff this
proposal has been hastily produced for “political expediency” (Jay
Crenshaw, personal comment, 12.11.07, Lewiston IDFG Open House to discuss
Draft Wolf Plan). The Idaho plan would allow for 73 breeding pairs to be
reduced to 15 breeding pairs. This is almost an 80% decrease in the wolf
population! Wolf populations are just beginning to make a solid comeback
within the Western United States. It seems counterintuitive to begin to plan
for significant decreases in a population so recently unstable. It seems even
more worrisome that this plan has been crafted on the basis of anecdotal,
isolated data. Most of the data used measured either ill-informed public
opinion or the health of the elk population. Neither of these data
compilations seems appropriate to support any wolf management plan. We urge
IDFG to reconsider this plan. We recommend IDFG consider putting forth a
management plan that is based on wolf data and seeks to promote the
well-being of Idaho’s wolf populations and ecosystems. Thank you for the
opportunity to comment on this proposal. Sincerely, Kirstin T. Eidenbach
Student, University of Idaho, College of Law Board Member, Friends of the
Clearwater
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