Friends and Colleagues:
The U.S. Fish and Wildlife Service (USFWS) has announced its
intention to establish a Distinct Population Segment of the gray
wolf in the Northern Rocky Mountains, and then delist this
population. A Distinct Population Segment (DPS) is essentially
a population of a species or subspecies of animal that occurs in a
specific geographic portion of that species' or subspecies' range.
The proposed Northern Rocky Mountain (NRM) DPS would encompasses all
of Montana, Idaho and Wyoming, plus the eastern one-third of
Washington, the eastern one-third of Oregon, and a small part of
north-central Utah. (To read the entire proposal go to:
http://frwebgate3.access.gpo.gov/cgi-bin/waisgate.cgi?
WAISdocID=†90366371+1+0+0&WAISaction==retrieve )
In response to this proposal Defenders crafted a comment letter,
which 12 additional environmental organizations supported and
signed onto. Highlights of our letter are as follows:
While we acknowledge that the NRM wolf population may constitute a
DPS, we are at this time strongly opposed to the delisting of this
population. The areas where we have greatest concern are :
• The lack of an approved state management plan in Wyoming
• The vagueness of the Idaho state plan
• The inclusion of portions of three additional states
(Oregon, Washington and Utah) that were not included in the original
recovery plan for the Northern Rockies
• Continued unstable wolf populations in northwestern Montana
and an apparent lack of connectivity with the Canadian wolf
population.
• The absence of an analysis regarding the effect disease may
be having on the NRM population.
(the letter in its entirety is pasted at the end of this message).
The comment period for this advanced notice is now closed. Due to
the complexity of this proposal, we were drafting our comments
right up to the deadline and were not able to formulate a message to
send to our members. We apologize for this; however, please note
that this proposal from USFWS was an `Advance Notice of Proposed
Rulemaking' which means that the USFWS will take the comments that
they received, repackage the proposal and put it out again for
public comment. When this updated version comes out we will provide
you with instructions on how to comment at that time.
We are entering into a new chapter of wolf recovery. The USFWS has
done a commendable job of restoring wolves to portions of their
former range within the NRM region. Conservation measures must
remain in place that ensure that this population stays healthy and
is allowed to expand into areas that still support suitable wolf
habitat. We must continue to address the concerns of those that
share the land with wolves, but we must also stay vigilant in our
efforts to continue the great strides we have made in restoring
wolves to the west. Please stay tuned for further updates!
For the wild ones,
Amaroq Weiss
Laura Jones
Defenders of Wildlife
_________________________________________________________
U.S. Fish and Wildlife Service
Western Gray Wolf Recovery Coordinator
585 Shepherd Way
Helena, Montana 59601
Re: RIN number 1018-RU53 Advance Notice of Proposed Rulemaking
regarding gray wolves in the northern Rocky Mountains
On behalf of Defenders of Wildlife ("Defenders"), Oregon Natural
Desert Association ("ONDA"), Klamath-Siskiyou Wildlands Center ("KS
Wild"), Gifford Pinchot Task Force ("GP Task Force"), The California
Wolf Center ("CWC"), Wolf Education and Research Center ("WERC"),
Western Watersheds Project ("WWP"), Oregon Natural Resources Council
("ONRC"), Friends of the Clearwater, Wolf Recovery Foundation
("WRF"), Hells Canyon Preservation Council ("HCPC"), Boulder-White
Clouds Council, ("BWWC"), and Cascadia Wildlands Project ("CWP"), we
thank you for the opportunity to comment on the U.S. Fish and
Wildlife Service's ("Service") advance notice of proposed rulemaking
("pre-proposal") to designate the Northern Rocky Mountain (NRM)
population of gray wolf as a distinct population segment (DPS) and
remove the NRM DPS of gray wolf from the federal list of endangered
and threatened wildlife.
Defenders is a national non-profit conservation organization with
more than 490,000 members and supporters nationwide. Ours is a
science-based advocacy organization focused on conserving and
restoring native species and the habitat upon which they depend, and
we have been involved in such efforts since our establishment in
1947.
ONDA is an Oregon non-profit public interest organization of
approximately 1000 members. It is headquartered in Bend, Oregon and
also has offices in Portland, Oregon. ONDA's mission is to protect,
defend, and restore forever the health of Oregon's native deserts.
ONDA has been actively involved in wolf recovery issues in Oregon,
and the members and staff of ONDA use and enjoy the natural
resources of eastern Oregon for many uses including wildlife
watching.
KS Wild is a non-profit organization located in southern Oregon with
more than 1,000 members. KS Wild has worked to protect the
outstanding biological diversity, including extirpated species like
the gray wolf, of the Klamath-Siskiyou and Southern Cascades regions
since 1997.
GP Task Force is a non-profit organization with over 3,000 members.
We work to preserve and restore the ecosystems and communities of
southwestern Washington by promoting conservation of forest
ecosystems and sustainable restoration-based employment.
CWC focuses on education, conservation and research relating to the
intelligent recovery of gray wolves in the western United States as
part of a broader effort to restore and maintain healthy north
American ecosystems.
WERC is dedicated to providing public education and outreach
concerning the gray wolf and its habitat in the Northern Rocky
Mountains. It is our goal to provide the public the opportunity to
observe and learn about wolves in their natural habitat. WERC's
interpretive visitor center provides an opportunity for our visitors
to interact with the staff and to experience some hands on education
opportunities by way of pelts, bones and replicas of skulls and
tracks.
WWP is an Idaho not-for-profit conservation organization with over
1,500 members. WWP owns and operates the 432 acre Greenfire
Preserve (a wildlife sanctuary), located on the East Fork Salmon
River near Clayton, Idaho and has offices in Hailey and Boise,
Idaho, Wyoming, California and Utah. The mission of Western
Watersheds Project is to protect and restore western watersheds and
wildlife through education, public policy initiatives and litigation.
ONRC, headquartered in Portland, Oregon, is a non-profit corporation
with approximately 5,000 members. ONRC's mission is to protect and
restore Oregon's wildlands, wildlife, and waters as an enduring
legacy. ONRC's goals include protecting the state's remaining old-
growth forests and roadless areas and restoring fully-functional
terrestrial and aquatic ecosystems with a full complement of native
species, including the gray wolf. ONRC works with a broad cross-
section of citizens, charitable groups, businesses, and government
agencies at all levels to incorporate environmental concerns into
democratic and economic institutions.
Friends of the Clearwater is a Moscow-based conservation
organization whose goal is education about and preservation of the
biodiversity and wildness of the public land in the Clearwater Basin
of north-central Idaho. Friends of the Clearwater's members are
mainly in the region but many are also scattered throughout the
United States. We have taken a keen interest in wolf recovery for
the past decade.
WRF is a 501(c)(3) non-profit corporation incorporated in the state
of Idaho. Our mission is to foster our heritage of wild wolf
communities by advocating their presence forever in places where
they have been extirpated. WRF advances its mission through efforts
in public representation, information and outreach, networking with
the agencies, organizations, tribes and universities, and through
workshops, conferences, special events, and comments on important
documents.
HCPC is a 501(c)(3) non-profit organization with a staff of 5 and
2,400 supporters. Our region of northeast Oregon includes the Hells
Canyon-Wallowa Mountains and Blue Mountains Ecosystems and this
region stretches well into the Payette National Forest in Idaho. We
work collaboratively with a variety of local organizations and
individuals, which lend credibility to our chosen work in La
Grande. Being close to local interests and agency decision making
processes is an advantage that other urban-bound organizations
simply don't have. One of our three major programs is Wolf
Recovery in Oregon and we have a significant legal interest in
protecting wolves in the Hells Canyon National Recreation Area as
well as in the surrounding land where they will likely recolonize
from Idaho.
BWCC was formed in 1989 to gain permanent protection for the 500,000-
acre Boulder-White Cloud Mountains by securing designation within
the National Wilderness Preservation System. We focus on protecting
and improving watersheds, fish and wildlife habitat. Our mission
includes providing accurate information on many issues to our
supporters, the public at large, media, elected officials, and other
conservation organizations in Idaho, the northern Rockies, the
Northwest, and nationally, including Washington, D.C.
CWP is a non-profit conservation organization founded in 1997 with
600 members throughout the United States whose mission is to defend
the forests, waters and wildlife of the bioregion by educating,
organizing and agitating for a more compassionate and responsible
relationship with the ecosystems of our bioregion.
We commend the Service for the remarkable achievement of restoring
wolves to portions of their former range within the NRM region, and
we encourage the Service to continue promoting the expansion of this
species across the remaining suitable habitat within the western
United States.
Our comments and questions are as follows:
I. WHETHER THE NORTHERN ROCKIES GRAY WOLF POPULATION QUALIFIES AS A
LISTABLE ENTITY AS A DISTINCT POPULATION SEGMENT.
We acknowledge that the U.S. northern Rockies gray wolf population
may constitute a Distinct Population Segment (DPS) as that term is
defined by the FWS/NMFS DPS policy.
First, there is no doubt that this wolf population is discrete from
the population in Canada based on an international boundary that
demarcates differences in control of exploitation, conservation
status and regulatory mechanisms, and we concur that morphological
differences seem to distinguish the wolves of the northern Rockies
from other wolf populations (e.g., higher percentage of wolves with
black pelage, on average are larger in size and weight than the
Mexican gray wolf, etc.). We also agree that this population is
separate from other wolf populations due to geographic and
ecological factors.
Second, there can be no question that the northern Rockies gray wolf
population is exceedingly significant to the taxon as a whole. Most
importantly, as one of only three existing gray wolf populations in
the coterminous U.S., the northern Rockies gray wolf population is
absolutely critical to the species' conservation in the U.S.
Moreover, this population persists in an ecological setting that is
vastly different from the wolf populations in the western Great
Lakes and southwest. For example, all three regions differ in
climate, vegetation, topography and prey. Climate, vegetation,
topography and major prey base are also different for wolves
dispersing outside of the core northern Rockies wolf recovery area.
Wolves traveling west from within the northern Rockies would
encounter high desert and then a Pacific maritime ecology. To the
south, wolves would encounter high desert and then rugged desert
terrain. To the east, they would encounter a prairie regime. Wolves
in the northern Rockies are thus significant not only for the gap
their loss would cause but also for the unique ecological setting in
which they reside.
However, because of the unique ecological setting of the northern
Rockies and the distinctly different ecological setting wolves
dispersing outside of the northern Rockies would encounter, the
Service should not sweep up portions of neighboring states as part
of a northern Rockies DPS merely to appease political concerns.
Instead, the Service must utilize the best scientific and commercial
evidence to ascertain appropriate boundaries within the northern
Rockies ecosystem. This is discussed in more detail below.
II. WHETHER DELISTING IS WARRANTED FOR THE NORTHERN ROCKIES GRAY
WOLF POPULATION.
At this time we strongly oppose delisting wolves in the northern
Rockies for the following reasons:
In October of 2005, the Service published a positive 90-day finding
in response to a petition filed by the state of Wyoming and the
Friends of the Northern Yellowstone Elk herd requesting the
establishment and delisting of a NRM DPS. During the ensuing public
comment period, Defenders submitted comments regarding the merits of
establishing a NRM DPS that included the states of Montana, Idaho
and Wyoming, and whether delisting that DPS was appropriate. We
stated then that we acknowledge that the northern Rockies gray wolf
population may constitute a DPS but oppose delisting that population
in light of Wyoming's inadequate wolf management plan. We continue
to oppose delisting of a NRM DPS until Wyoming's wolf plan is
modified to meet conservation standards. In addition, we continue
to have significant concerns regarding Idaho's plan, which we
expressed in comments submitted during a public comment period held
in 2002 (a copy of our comment letter on Idaho's plan is attached).
We remain deeply concerned by the vagueness of the Idaho wolf
management plan and by the state's official position on wolves, set
forth in the opening pages of the state wolf plan: The 2001 House
Joint Memorial 5 that calls for the removal of all wolves from Idaho
by "whatever means necessary." The Idaho state wolf plan also
authorizes state management dependent on federal funding, which is
not expected to be secured upon delisting. Beyond our ongoing
concerns about the state wolf plan for Wyoming and Idaho, however,
we also have strong concerns regarding the incorporation of portions
of three additional states to create the proposed NRM DPS. These
and other issues are discussed in more detail below.
A. Wyoming's state wolf plan is insufficient.
The Service cannot delist the proposed NRM DPS until Wyoming's state
plan meets the regulatory requirements of the Endangered Species Act
(ESA). Federal approval of Wyoming's state wolf plan has not been
given because the Service rightfully shares the concerns of
conservation groups that Wyoming's state wolf plan fails to provide
adequate regulatory mechanisms to assure that the state's wolf
population would remain viable. On July 15, 2002, we submitted our
comments to the Service regarding the inadequacy of Wyoming's state
plan. To date, the state has failed to make necessary changes (a
copy of our comment letter on Wyoming's plan is attached). The
failure of Wyoming to prevail in its lawsuit challenging the federal
government's refusal to approve their wolf plan has not stimulated
the necessary changes to the plan. Despite Wyoming's intransigence,
for a state wolf plan to be accepted by the Department of the
Interior it must meet minimum federal statutory standards,
specifically those required under the Endangered Species Act.
As the state has yet to remedy any of the concerns expressed in our
comment letter and by the Service, we remain strongly opposed to
Wyoming assuming primary management control of wolves within their
borders. The only Service-approved state plans in the northern
Rockies at this time are from Idaho and Montana. By its own
repeated assertions in federal documents pertaining to wolf recovery
in this region, the Service shall not delist wolves regionwide
without Wyoming completing a state plan in compliance with the ESA.
Should the Service consider a DPS designation or delisting of Idaho
and Montana without Wyoming, our concerns regarding this potential
option are set forth below.
B. Idaho's State Wolf Plan is Insufficient and its Management
Actions are Flawed.
We additionally have significant concerns regarding Idaho's state
wolf plan and expressed those concerns in our comments submitted to
the Service in 2002. Idaho's state wolf plan sets forth in its
introductory pages the official position of that state which is to
remove wolves "by any means necessary" and the state plan allows for
removal of all wolves down to the 15-pack safety margin the state
agreed to maintain. At current wolf population levels in Idaho,
this would result in the allowable killing of two-thirds of Idaho's
current wolf population. Indeed, Idaho's first proposed wolf
management action upon assuming management authority in January 2006
under a Memorandum of Agreement with the Department of the Interior
was to kill 75% of the wolves in the Clearwater National Forest to
increase the resident elk population. This decision was made
despite overwhelming scientific opinion that habitat conditions, not
predation, have been responsible for elk decline in that region. If
Idaho (and/or Montana, whose state plan allows for a similar
reduction in pack numbers but has a stronger pro-conservation wolf
management plan) takes deliberate actions to remove significant
numbers of wolves, long-term viability and success of the program
would be jeopardized.
C. The Inclusion of Portions of Three Additional States That Were
Not Included in the Original Recovery Plan for the Northern Rockies
Requires Further Examination.
The proposed NRM DPS expands the region designated as the Northern
Rockies Recovery Area to include the eastern one-third of Washington
and Oregon and a small portion of north-central Utah. This was done
despite repeated assertions by the Service over the years that wolf
recovery in the northern Rockies does not require the inclusion of
Washington or Oregon (USFWS 1980, USFWS 1987, USFWS 1994, USFWS
2003). Further, the Service has included portions of these states
in the DPS while simultaneously stating they do not include suitable
wolf habitat and would not contribute to the wolf's habitation of a
significant portion of its range within the proposed NRM DPS. While
the Service's intent in including the additional states may be to
create a buffer for dispersal of wolves from the northern Rockies
core population, instead their boundary placement arbitrarily severs
a crucial travel corridor for wolf dispersal from the northern
Rockies to the west. In the absence of federal safeguards, unless
there are adequate state protections in place, wolves will likely be
subject to high mortality levels jeopardizing population viability
and dispersal.
The placement of the proposed boundaries for the DPS raises
significant questions, not the least of which is whether the
Service's expansion of the boundaries from the original northern
Rockies recovery area requires a corresponding expansion of
population recovery goals for the newly-included areas. Another key
question is what the Service intends to do regarding federal
protections outside the NRM DPS once that region is delisted. Other
essential questions include the following:
• Will the Service insist that all states within the DPS have
Service-approved wolf plans prior to downlisting?
• Will the Service require that wolves be present in all
states that are part of the DPS prior to downlisting?
In addition to the above overarching questions, specific questions
regarding the designated boundaries merit answers:
• Why does the Service use roads to set boundaries on the West
side of the DPS in Oregon and Washington and on the South side where
the boundary dips into Utah, and state lines on the East side?
• Is there a biological basis for using roads to demarcate DPS
boundaries?
• Are there natural features that would better delineate the
boundaries?
• Did the Service consider using the Snake and/or Columbia
Rivers as boundaries?
Answers to these questions are needed before we can adequately
comment on the proposed boundaries of the NRM DPS.
D. Changing goalposts, unstable populations in northwest Montana,
and disease.
The foundation of population viability is representation,
redundancy, and resiliency. While the number of wolves in the
northern Rockies has grown significantly over the last decade, the
original premise scientists used to establish recovery goals for the
NRM wolf population has not yet been realized: the connectivity
between the northern Rockies and southern Canadian wolf meta-
population . In the 1994 Environmental Impact Statement (EIS)
review, Dr. Steve Fritts, EIS Team Wolf Scientist and Northern Rocky
Mountain Wolf Recovery Coordinator, bases the Service's population
goals for wolves in the northern Rockies on a premise that this
population "would be connected to the Canadian population via the
Rocky Mountain chain northward from Glacier National Park [in
Northwest Montana] to the Banff Jasper Parks in Alberta and B.C."
(USFWS 1993). Dr. Fritts concludes "That corridor may be vital to
the long term future of wolves in the Northern Rockies of the U.S."
(USFWS 1994a). The Service also conducted a review by a "wide
diversity of professional peer reviewers" who concluded that some
minimum level of connectivity among the U.S. subpopulations and with
the larger wolf population in Canada was necessary to guarantee long-
term persistence" (USFWS 2003). Instead of guaranteeing this
connectivity, the northwest Montana wolf population has lagged
significantly behind the other wolf recovery areas (central Idaho
and the Yellowstone ecosystem) due to heavier use of lethal control
at low population levels and illegal killing.
While the Service's pre-proposal claims that there is connectivity
with the Canadian wolf population, it only references two dated
studies: Pletscher et al 1991 and Boyd and Pletscher 1997. However,
Dr. Dan Pletscher has recently identified that there appears to be a
troubling lack of connectivity between the Canadian wolf population
and the NRM wolf population (D.Pletcher, personal communication,
March 2006). In light of this more recent information, we believe
that the lack of connectivity with the Canadian wolf population
remains a critical issue as it relates to population viability and
gene flow that the Service must adequately address before delisting
the NRM wolf population.
The northern Rockies gray wolf recovery zone, designated as the two
reintroduction areas of Yellowstone National Park and central Idaho,
plus the naturally-recolonized region of northwestern Montana, were
intended to achieve viable population status, with three discrete
wolf populations reproducing, dispersing, and providing genetic flow
between the three regions and the wolf population in Canada
sufficient to meet scientific standards for a viable meta-
population. While the reintroduced 10(j) populations in central
Idaho and Yellowstone National Park have flourished, the fully
endangered wolf population in northwestern Montana has stagnated, in
part due to the heavy reliance by the Service on lethal control of
wolves in this region. As a result, the Service has not reached
population goals outlined in the recovery plan of 10 breeding pairs
for three consecutive years in each of these three regions nor has a
reliable link to the Canadian wolf meta-population been established.
Rather than amend its heavy reliance on lethal control of wolves,
the Service instead changed the population goals to 30 breeding
pairs across the three regions for three consecutive years.
Though the overall population of the northern Rockies recovery area
has reached nearly 1000 wolves at the end of 2005, the population in
northwestern Montana has not shown a constant upward trend but has
instead, starting from a recorded population of 66 wolves in 1995,
peaked at an estimated 108 wolves in 2002 and then declined again by
54 percent to only 59 wolves in 2004. The Service has thus relied
on the two other regions within the northern Rockies recovery area
to meet their new, redistributed goals. Yet, one of these other
areas, Yellowstone National Park, has itself seen a downturn in the
wolf population in the last year. Following the conservation biology
principles of redundancy, representation and resiliency, a
population decline in two of the three geographic areas within the
recovery zone is of significant concern.
In Yellowstone National Park, the wolf population is down from 171
wolves in 16 packs in 2004 to only 113 wolves in 11 – 13 packs in
2005. Pup survival in Yellowstone this past year is at a low of 19
pups within the entire park, after a spring that saw the birth of 28
pups. According to National Park Service wolf biologists, a high
incidence of disease, parvo, seems to be responsible for the high
level of pup mortality this year.
In addition, mange has reportedly been recently discovered in wolves
in the Payette National Forest in Idaho. Though the Service's NRM
DPS pre-proposal included some discussion of the potential impacts
of disease on the region's wolf population, this pre-proposal was
issued prior to the discovery of mange in Idaho. A thorough
analysis should be conducted regarding the status and severity of
this new disease outbreak. With two distinctly different diseases
(mange and parvo)-- each capable of negatively impacting the
region's wolf population -- appearing in two separate areas of the
recovery area, an analysis of their combined potential impact on the
wolf population is warranted.
E. Insufficient elapsed time to judge genetic flow among the three
regions.
Too little time (in wolf generations) has elapsed to accurately
assess the genetics of the northern Rockies wolf population as
reliable evidence for the existence or lack of connectivity among
the three-state area and with Canada. Genetic researchers have
recently characterized over 500 individuals from the 1995
reintroduced Canadian wolves through individuals sampled in 2005.
They determined that Montana, Idaho and Yellowstone populations
are "genetically distinct" and while some limited migration has
occurred, "genetic exchange has been minimal and the populations
remain effectively isolated from each other" (Von Holdt et al 2006).
F. Risk of state management plans becoming unfunded, and therefore
unenforced, mandates.
Before the Service can seriously consider creating and delisting an
NRM DPS, the Service must be assured that adequate funding will be
available to implement and enforce the wolf conservation measures
set forth in the Idaho, Montana and Wyoming state management plans.
Moreover, because state-funding of wolf management programs are key
to the long-term success of the recovery efforts, only the funded
aspects of the state management plans can be properly considered in
the Services' delisting calculus. In other words, the Service
cannot rely on unfunded mandates or otherwise meaningless regulatory
mechanisms to justify the delisting of an NRM DPS. Funding is
necessary to assure appropriate monitoring of the wolf population as
it changes over time. This need is especially apparent in light of
Idaho's announced intention to reduce their state wolf population by
two-thirds down to the minimum 15 breeding pairs their plan requires.
III. CREATING A NRM DPS THAT INCLUDES IDAHO AND MONTANA BUT
ENTIRELY EXCLUDES WYOMING OR INCLUDES ONLY THOSE PORTIONS OF WYOMING
THAT ARE SOLELY UNDER FEDERAL CONTROL.
The Service has consistently, throughout recovery planning, EIS's
and subsequent scientists' peer reviews maintained the necessity of
a tie among the states of Montana, Idaho and Wyoming, for
constructing an interconnected metapopulation of wolves in the
northern Rockies. Any attempt to parcel out a delisting for the
states of Idaho and Montana simply because the state of Wyoming
refuses to modify its state wolf plan and state laws to assure an
adequate regulatory mechanism for wolf conservation and management
would be politically motivated and is expressly outlawed by the ESA
which requires that listing and delisting decisions be based only
upon the best available scientific and commercial data.
IV. ADDITIONAL ISSUES REQUIRING CONSIDERATION BY THE SERVICE.
Placing the westernmost edge of the boundary for the proposed NRM
DPS in an area the Service suggests is a wolf sink seems difficult
to justify biologically. The Service is aware of several studies
documenting suitable wolf habitat in western Oregon and western
Washington (Carroll et al., 2001; Larsen, 2004; Carroll et al.,
2006), and its placement of the western boundary line appears
designed to operate as a moat to keep wolves from dispersing
westward, rather than a bridge to aid in natural dispersal and
recovery into the Cascades and beyond. As currently placed, the
boundary cuts across critical wolf dispersal corridors in
northeastern and southeastern Washington, and in northeastern
Oregon. At the very least, the boundary placement should not act as
a potential impediment to wolf dispersal westward.
Viewing the proposed boundaries from the perspective of state
wildlife agencies in Oregon, Washington and Utah, additional
significant concerns arise. The Service is well aware of the Oregon
wolf plan's inclusion of a dividing line near the center of the
state for management purposes under state law. Placing the NRM DPS
boundary line within the state of Oregon yet to the east of the
state plan dividing line will create serious management difficulties
for the Oregon Department of Fish and Wildlife, and extreme
confusion for Oregon citizens, as it effectively results in three
potentially differing management treatments. And, even with no
state plan yet in place, the Washington Department of Fish &
Wildlife opposes the Service creating two different management
scenarios within the state by drawing the western boundary across
the eastern one-third of Washington. Similar concerns are being
raised by stakeholders in Utah. While it is correct that the states
of Idaho and Montana have lived under management regimes that differ
in different parts of those states, these states have always been
part of the northern Rockies Recovery Area for wolves, with goals
set for wolf populations and standards set for state wolf plans.
This is not true of the adjacent states that are now under
consideration for inclusion in the proposed NRM DPS and there is no
biological or legal justification for imposing a split state
management regime in these states.
V. SUMMARY.
We acknowledge that the Northern Rockies Recovery Area may qualify
for designation as a DPS but is opposed to any reduction or removal
of federal protections in the region prior to Wyoming adopting a
state wolf plan that meets ESA standards to assure adequate
regulatory mechanisms are in place and threats against the wolf have
been addressed. In addition, Idaho must strengthen its wolf
management plan to remove the House Joint Memorial 5 and clarify and
enhance its conservation objectives
The boundaries proposed for the NRM DPS raise numerous significant
questions that must be answered by the Service before the public can
adequately comment on the area included within the boundaries.
The areas outside of the original northern Rockies recovery area
should be viewed as potential areas for dispersal that must retain
full federal protections for wolves that migrate beyond the northern
Rockies core habitat and which provide the genesis for wolf recovery
in the Pacific western states of Washington, Oregon and California,
as well as Nevada and Utah.
We oppose any attempt to create a DPS that includes Idaho and
Montana but which excludes any or all portions of Wyoming.
We recommend the Service create a NRM DPS that focuses on that area
that is deemed necessary for the long-term success of northern
Rockies wolf recovery efforts. To the extent possible by law, and
justifiable biologically, the boundaries of the DPS should remain
within the states of Idaho, Montana and Wyoming. In addition, the
Service should require the development of wolf conservation and
management plans in compliance with the ESA, prior to reduction or
removal of federal protections for wolves in the NRM DPS. Should
the Service include portions of adjacent states beyond those
historically contemplated, it needs to recalibrate the population
goals and occupation of the DPS landscape necessary to ensure long-
term viability.
Thank you for the opportunity to provide comments on the Service's
proposed designation of a NRM wolf DPS.
Sincerely,
Wm. Robert Irvin
Senior Vice-President Conservation Programs
Defenders of Wildlife
1130 Seventeenth Street, NW
Washington, DC 20036
202-682-9400
http://www.defenders.org
Kristin Ruether, Staff Attorney
Oregon Natural Desert Association
917 SW Oak Street, Suite 409
Portland, OR 97205
503-525-0193
http://www.onda.org
Joseph Vaile, Campaign Director
Klamath-Siskiyou Wildlands Center
P.O. Box 102
Ashland, OR 97520
541-488-5789
http://www.kswild.org
Ryan Hunter, Program Director
Gifford Pinchot Task Force
917 SW Oak St., Suite 410
Portland, OR 97205
503-221-2102 ext. 101
http://www.gptaskforce.org
Patrick Valentino, Executive Director
California Wolf Center
P.O. Box 1389
Julian, CA 92036
619-234-9653
http://www.californiawolfcenter.org
Roy Farrar, CEO
Wolf Education and Research Center
111 Main Stree, Room 150
Lewiston, ID 83501
208-743-9554
http://www.wolfcenter.org
Jon Marvel, Executive Director
Western Watersheds Project
P.O. Box 1770
Hailey, ID 83333
208-788-2290
http://www.westernwatersheds.org
Doug Heiken, Field Representative
Oregon Natural Resources Council
5825 N. Greeley Ave.
Portland, OR 97217
503-283-6343
http://www.onrc.org
Gary Macfarlane, Ecosystem Defense Director
Friends of the Clearwater
PO Box 9241
Moscow, ID 83843
208-882-9755
http://www.wildrockies.org/foc/
Ralph Maughan, President
Wolf Recovery Foundation
PO Box 444
Pocatello, Idaho 83204
Mike Medberry, Executive Director
P.O. Box 2678
La Grande, Oregon 97850
541-963-3950
http://www.hellscanyon.org
Lynne K. Stone, Director
Boulder-White Clouds Council
Box 6313
Ketchum ID 83340
http://www.wildwhiteclouds.org
Josh Laughlin, Executive Director
Cascadia Wildlands Project
POB 10455
Eugene, OR 97440
541.434.1463
http://www.cascwild.org
Literature cited
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United States Fish and Wildlife Service. 1980. Northern Rocky
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of gray wolves to Yellowstone National Park and Central Idaho: Final
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United States Fish and Wildlife Service. 2003. Final Rule to
designate 3 District Population Segments and change the ESA status
of the Gray Wolf throughout most of the lower 48 states. Federal
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Addendums
Defenders' comments regarding the Idaho state wolf management plan
Defenders' comments regarding the Wyoming state wolf management plan