Declaration of Edward E. Bangs
In this group of four posts we give selected excerpts from the testimony of wildlife biologists, experts in wolf biology. The testimony was solicited in regards to the lawsuit brought by enviro groups to enjoin the delisting (removal from the Endangered Species List) of Rocky Mountain wolves. The Plaintiffs prevailed last July when U.S. District Judge Donald Molloy granted a preliminary injunction, throwing out the delisting of gray wolves in the Northern Rockies and ordering them put back on the Endangered Species list. [here]
Judge Molloy set himself up as a wolf expert and disregarded the testimony of the actual authorities, upon whom the USFWS is legally bound to rely. We post what the real experts had to say in order to reveal just how egregious and unsound Judge Molloy’s decision was.
Selected excerpts from the DECLARATION OF EDWARD E. BANGS to the UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA, MISSOULA DIVISION (Bang’s entire Declaration is [here]).
I am a wildlife biologist employed by U.S. Fish and Wildlife Service [USFWS] as a Wolf Recovery Coordinator. In this capacity I was responsible for overall coordination of all wolf-related activities in the Northern Rocky Mountain [NRM] Distinct Population Segment [DPS] prior to the delisting of the NRM DPS. Previously, I was the USFWS project leader for wolf management in Montana from 1988-1992. I led preparation of the Congressionally-mandated Environmental Impact Statement [EIS] (USFWS 1994) to reintroduce wolves to Yellowstone National Park [YNP] and central Idaho from 1992-1994. I was the project leader for the reintroduction of wolves from 1994-1996, and have been the Wolf Recovery Coordinator for the NRM since 1995. …
I worked on wolf research and conservation issues, including regulated public harvest of wolves, on the Kenai National Wildlife Refuge in Alaska from 1975-88. Wolves on the island-like Kenai Peninsula were extirpated by 1920. They eventually naturally recolonized the 10,000 square mile Peninsula in the mid-1960s by natural dispersal through a 10 mile-wide land/ice-bridge from the Alaska mainland (Peterson et al. 1984). That wolf population grew to as many as 200 wolves that occupied all suitable habitat by the late-1970s. The wolf population has remained relatively stable through the present time. Wolves there have been harvested under State and Refuge hunting and trapping programs since the mid-1970s. Harvest slightly reduced wolf density for a short period of time in the early 1980s, but since that time the wolf population has remained relatively stable and has been regulated largely by natural factors- despite ongoing liberal public hunting and trapping programs. Despite very few founders, very limited, if any, additional wolf dispersal to the Kenai Peninsula, and continued high levels of human-caused mortality the Kenai Peninsula population remains robust and viable. No conservation concerns have been documented in the past 50 years related to the extremely limited habitat connectivity or genetic viability (Talbot and Scribner 1997). …
The NRM wolf population currently contains approximately 1,513 adult wolves, plus their pups born in spring 2008, in at least 192 packs, 107 of which were classified as breeding pairs in 2007 (Service et al. 2008). The USFWS defines a breeding pair as a pack containing at least an adult male and an adult female and at least 2 pups on December 31. The foundation of any viable population is successful breeding and recruitment into the population so the metric of a breeding pair was developed to ensure biologically meaningful recovery criteria (Mitchell et al. 2008). …
The NRM DPS meta-population consists of wolves in the core recovery areas of northwestern Montana, central Idaho, and the Greater Yellowstone Area [GYA] that includes northwestern Wyoming, southwestern Montana, and southeastern Idaho. Natural wolf dispersal occurs routinely between Canada, northwestern Montana, central Idaho and the GYA. Dispersal to the GYA occurs less frequently than between the other areas but likely occurs annually. Biologically, the NRM wolf is simply a 400 mile southern extension of the vast healthy and harvested adjacent Canadian wolf population. …
Delisting and subsequent State management will not result in a harmful decline in the NRM wolf population from its current level. An important factor in the USFWS decision to delist the NRM DPS was the commitment made by Montana, Idaho, and Wyoming in their USFWS-approved wolf management plans to each maintain at least 150 wolves and at least 15 breeding pairs in each State and to manage all threats so that the NRM DPS would never again be threatened with extinction. Soon after the post-delisting wolf management plans were approved by the USFWS, the States began developing stepdown objectives for management and implementation (including control and public hunting regulations). The USFWS has repeatedly evaluated what a recovered wolf population is and how to measure it and a 3-segmented wolf population that never falls below 10 breeding pairs and 100 wolves per segment [at least 30 breeding pairs and at least 300 wolves], by its very definition, such a wolf population would always be biologically viable and could never be considered threatened or endangered. …
In spring 2008, 440-535 wolf pups were likely born and added to the NRM wolf population. This conservative estimate assumes, based on data over the past 20 years, that at least the 107 known breeding pairs in 2007 will produce an average of 5 pups each, and, on average, 4 pups will survive until winter (USFWS et al. 2008). A comparison of theoretical suitable wolf habitat (Oakleaf et al. 2005) and current wolf distribution (Service et al. 2008) indicates the NRM will remain saturated with resident wolf packs…
The absence of wolf breeding pairs in the 88% of Wyoming where the wolf is designated as a predatory animal has no impact on Wyoming’s ability to maintain its share of the GYA meta-population segment because that area is largely highly unsuitable wolf habitat (Oakleaf 2007) and it is not located between the core recovery areas so it cannot effect the rate of natural dispersal between the three core recovery areas. …
Since 1995 the NRM wolf population has increased at a rate of about 24% annually. …
Wolf populations are naturally highly resilient to mortality events because of their adaptable social structure and behavior and their potential for high reproductive rates and high pup survival. Wolf populations can maintain themselves despite annual human-caused mortality rates of 30% to 50% (Brainerd et al. 2008; Fuller et al. 2003). Wolf populations below habitat carry-capacity can quickly expand, sometimes nearly doubling within one or two years, following sharp declines caused by temporarily high rates of human-caused mortality or other causes. …
About 200 of the 1,500 wolves present in the NRM in 2007 lived in National Parks. YNP, perhaps the best area in the world to easily view wild wolves, is unaffected by delisting. Because wolf packs rarely leave YNP and usually only for short periods during time-periods when hunting is closed, resident Park packs will be largely unaffected by human-caused mortality resulting from the delisting of the NRM DPS and the implementation of State hunting seasons. …
If the NRM wolf population continued to grow at typical rates [24% per year] and given a 10% rate of agency-authorized removal of wolves that depredate on livestock and pets, there would likely be over 1,800 wolves in the NRM by fall 2008 when the first State-regulated hunting would begin. The level of public hunting as proposed by the States could not possibly threaten the NRM wolf population. …
The States of Montana, Idaho, and Wyoming plan to implement regulated wolf hunting seasons, which will be closely managed based upon the health and size of the respective wolf population within each State. Similar public hunting seasons have been successfully used to help manage and conserve other resident wildlife in those States including mountain lions, black bears, elk, and deer. Such wolf hunting will not begin until the fall of 2008 and would not threaten the wolf population. …
Wolves in some areas of the world prey extensively on livestock, which generates tremendous local public animosity (Fritts et al. 2003). A critical part of the NRM wolf recovery and conservation program is the control of wolves that attack livestock and other domestic animals to maintain public tolerance of wolves (Bangs et al. 2004, 2005). …
In recent years we have killed a higher percentage of the wolf population each year because most suitable habitat –- where conflicts are least likely — is already occupied by resident wolf packs. Yet the overall NRM wolf population has still increased at a rate of 24% annually.
Because most suitable habitat is occupied by resident packs, dispersing wolves try to establish new packs in unsuitable habitat where chronic conflicts with livestock are likely. As new wolf packs try to reestablish themselves in areas, such as open heavily grazed agricultural land in southern Wyoming, where conflict is likely to be chronic, those wolves must continue to be removed by agency and private control. If the wolf population continues to grow the number of domestic animals and livestock killed, the economic losses, and the level and cost of agency control required to resolve those conflicts will all occur at an increasingly higher rates. …
The NRM system is a functioning meta-population composed of three core recovery zones. Wolves have been documented to disperse between its segments and even without any dispersal between them each segment is large enough, genetically diverse enough, and has enough secure suitable wolf habitat to never be threatened or endangered. …
Conservation of a metapopulation does not require solely or any natural dispersal as the plaintiffs allege. Because of its location, that area of Wyoming where wolves are designated as predatory animals is immaterial to maintaining the potential for natural wolf dispersal between the core population segments. …
The plaintiffs allege the USFWS peer reviews of recovery goals were biased. … The experts selected to review the earlier recovery goal analysis by Fritts (Service 1994), the State wolf management plans, and the final delisting rule, including the recovery criteria, are recognized as among the most experienced and professional wolf and conservation biologists in North America. Virtually none of those experts ever suggested a wolf population must contain 2,000-5,000 wolves to be considered viable or recovered. The scientific peer review conducted throughout this process was unquestionably transparent, thorough, professional, and objective, and exceeded routine scientific standards for peer review…
YNP is saturated with wolves and there is simply no room left for wolves to disperse into YNP, logically explaining the past limited evidence of genetic or radiocollared wolf dispersal into YNP itself. However, while YNP is 3,400 square miles in size and contained 171 wolves in 2007, it is a fraction of the GYA which is 25,000 square miles in size and contained approximately 432 wolves in 2007. Wolves in National Parks remain fully protected by Park regulations regardless of delisting. …
The vonHoldt et al. (2007) analysis clearly demonstrated that wolves in the Park deliberately outbreed to maximize genetic diversity and the current population is extremely genetically diverse and absolutely no problems currently exist. …
It assumed that the USFWS or States would fail to recognize connectivity as a potential conservation issue (the vonHoldt et al. paper was published before the Final Rule was completed). On the contrary the Final Rule contained extensive literature review and analysis of potential connectivity and genetic issues, as well as an analysis of the State’s commitments to fully address such issues if they ever arose…
[A] thorough factual review of those specific vonHoldt et al. predictions [as was conducted in the final delisting rule] clearly demonstrates that the NRM wolf population will not be threatened or endangered in the foreseeable future by habitat connectivity, wolf dispersal, or genetic viability, even without the promised management intervention by the affected States if it was ever needed. …
The 2007 Wyoming wolf plan is a solid science-based conservation plan that will adequately conserve Wyoming’s share of the GYA wolf population so that the NRM wolf population will never be threatened again. …
All wildlife populations have social structures and wolf social structure becomes symbolically important to people
because they believe it closely resembles human social structure. In contrast to the plaintiffs’ allegations of the fragile nature of wolf packs, our paper and other intensive work clearly demonstrated how amazingly resilient wolf pack structure is to losing breeders and population turnover (Brainerd et al. 2008; Mech 2003; Mech 2006). …Packs quickly replace breeders and pack members can easily successfully raise pups if breeders are lost. This adaptable social structure is one the primary reasons wolves are such an adaptable, successful, and resilient species. Wolves throughout most of the world are often killed by people and wolf populations remain viable. Most wolf populations in North America (representing about 60,000 wolves) and in other parts of the world are hunted, trapped, and individual wolves are killed through a wide variety of other methods by people. Wolf biologists know a tremendous amount about the impact of various rates of human-caused mortality on wolf social structure, wolf packs, and wolf populations (Fuller et al 2003). Loss of breeders may be a concern in very small recovering wolf populations that are at low density, with fewer than 75 wolves, in packs smaller than 6 wolves that contain 3 or fewer adults, and when pups are less than 6 months old. However, none of these conditions apply in the NRM where there are over 1,500 wolves; wolves are at high density; suitable wolf habitat is saturated with resident wolf packs; and pack size averages 10 members in more protected areas like Parks, wilderness areas, and remote public lands, and 6 members per pack outside of those types of areas in winter — after most annual wolf mortality has occurred (Service et al 2008). …
In conclusion, State management after delisting will not threaten the NRM wolf populations long-term survival based on the States’ written commitments in their wolf management plans, including regulating the rate of agency and private wolf control allowed under State law. …
