3 Dec 2008, 2:44pm
by admin

MSSA Comments On Wolf Delisting (Again)

The Montana Shooting Sports Association submitted the following comments to the U.S. Fish and Wildlife Service regarding the delisting of wolves in Montana. Comments were due by Nov 28, 2008, but additional comments my be accepted. Please see the U.S. Fish and Wildlife Service announcement [here].

November 12, 2008

Subject: “RIN number 1018-AU53″

U.S. Fish and Wildlife Service
Western Gray Wolf Recovery Coordinator
585 Shepard Way
Helena, Montana 59601

In re: Comment — Canadian Wolf Delisting and Designating the Northern Rocky Mountain Population of Wolf as a Distinct Population Segment.

Submitted electronically.

Dear Sirs,

The Montana Shooting Sports Association (MSSA) is the primary organization asserting the rights and prerogatives of hunters in Montana. MSSA has members throughout Montana. MSSA was opposed to the initial “introduction” of Canadian Wolves into Montana, supports the earliest removal of these wolves from protection by the federal government, and opposes any Distinct Population Segment designation for the following reasons:

First, MSSA incorporates by reference here all comments previously submitted on March 31, 2006. Those comments are posted at: http://www.mtssa.org/wolfdelist.phtml

Second, MSSA has the following additional comments to add to the record:

Argument has been made that “genetic diversity” and “genetic connectivity” of wolf populations must be assured before wolves may be delisted in the northern Rocky Mountains. We assert that these conditions are not required under the Endangered Species Act. We also assert that there currently exists sufficient “genetic diversity” and “genetic connectivity” of Northern Rockies wolf populations to pass any rational, unbiased test. We assert that wolf advocates had years to raise these issues, but either slept on their rights or committed fraud though deliberate silence.

Further, wolf introduction efforts, coupled with failure to delist, does has never adequately addressed the issues of wolf transportation and transmission of disease and parasites that may affect people, domestic animals and other wildlife.

Finally, the introduction of Canadian wolves into the Northern Rockies may have eradicated the different and endangered wolves already living here, making the release of Canadian wolves itself a violation of the Endangered Species Act.

Genetic diversity. This topic is over-hyped. Those involved in animal husbandry will affirm that genetic diversity is not any sort of prime requirement for healthy animal populations. Many animal breeders actually concentrate bloodlines in order to produce desirable traits in offspring, without any species degradation. This has been done since before biblical times.

In addition, scientific testimony was presented in the lawsuit in federal court to reverse the previous delisting effort to document that some populations of wolves begun in isolated location(s) with only one male and one female, and with no additional injection of genetic material, are thriving - that lack of genetic diversity is no handicap to species survival whatsoever.

Further, the Canadian wolves that were released in Montana by the USFWS were drawn from several different parts of Canada, giving that released population a genetic diversity base far exceeding that necessary for a healthy population.

Actual practice and historic observation inform us that the only genetic diversity issue of any real consequence whatsoever is that there be both males and females. Once that diversity threshold is achieved, all rational genetic diversity needs have been met.

Those who advocate genetic diversity have offered no proof that genetic diversity among wolves is either desirable or necessary. If genetic diversity is so important, why has it taken wolf advocates over a decade to discover and articulate it? Why was argument for genetic diversity not made when the Endangered Species Act was crafted, or when the several state wolf management plans were devised? If the argument of genetic diversity has been apparent to the wolf advocates for a decade but they have deliberately not raised it until the 11th hour could that long silence be a type of fraud?

Genetic diversity is a thin, ruse argument. It is grasping at straws. Anyone who claims merit in that argument is either agenda-driven and using the argument as a facade, or they are living in la-la land.

Genetic connectivity. This argument is also a ruse. First, wolves social makeup is strongly antagonistic to genetic connectivity. Wolves regularly and reliably kill other wolves, with other genetic makeup, that stray into the area claimed by a pack. So, wolves actively resist genetic connectivity, no matter how much nature-loving environmental activists wish it were otherwise.

Second, without need for genetic diversity, as discussed above, there is simply no need for genetic connectivity.

Third, there is already a potential for genetic connectivity that is probably an order of magnitude greater than anything that might be required for a genetically-stable population. For example, a few years ago a wolf collared and released in Montana was found as road-kill in Texas. This wolf had traveled an incredible distance.

There are three populations of wolves discussed in the Northern Rockies; the population migrating from Canada in northwestern Montana, the population introduced into the Yellowstone Park area, and the introduced population in central Idaho. There are documented wolf packs west of Missoula, both north and south of Interstate 90, and area that is roughly equidistant from the three general populations mentioned preceding. It is axiomatic to presume that the wolves west of Missoula came from one of the other three wolf population centers. Ergo, if wolves can reach the center of the existing population triangle, wolves are then quite capable of reaching any part of the triangle from any other part of the triangle. To say otherwise is to defy rational thought.

If there is inadequate intermingling of wolf genetics (according to some), it is mostly because wolves kill strange wolves at the first opportunity. Perhaps the advocates of genetic connectivity ought to be assigned the task to force the mating of wolves strange to each other (sorry, no protective clothing or protective devices allowed). Let’s get on the record just how well wolves tolerate that.

Laches. Wolf advocates have long known terms of delisting. Those objecting to delisting had years to raise new issues concerning delisting, but they never did. They cannot claim ignorance of pending delisting. There have been multiple opportunities to new raise issues in comment on state management plans, listing and delisting, yet genetic diversity and genetic connectivity have never before been central to the wolf advocates’ position. See laches and 1-3-218, M.C.A., “Vigilance. The law helps the vigilant before those who sleep on their rights.”

Disease and parasites. Precious little attention has been paid to the diseases and parasites for which wolves may be vectors. Wolves are certainly hosts to or potential vectors for many dangerous diseases and parasites that affect other wild animals, livestock and humans, e.g. distemper, rabies, anthrax, brucellosis, echinococcus granulosis, and others. Because wolves are so highly mobile, their role as vectors is a huge liability to other species also subject to the diseases and parasites they may carry. Therefore, the potential exists for wolves to have a vast and incalculable negative impact upon other species, domestic, wild, and of course, humans.

For more information about disease and parasite transmission, I reference Wolves in Russia by Will Graves, and incorporate that book by reference in this comment.

I submit that the liability associated with far-ranging wolves as disease and parasite vectors argues strongly for aggressive wolf management by the affected states.

Eradication of native wolves. In her book Yellowstone Wolves, Cat Ubrikit makes a compelling case that a separate subspecies of wolf inhabited the greater Yellowstone area, including Montana and Wyoming, than the subspecies of Canadian wolf released by the FWS. This subspecies looks different, has different social structure, and hunts differently. There is a history of far too many documented sightings of this native subspecies for there to be any rational doubt that it existed prior to the release of Canadian wolves. Facing the near-certainty that this native subspecies existed and inhabited Montana and Wyoming, then the thoughtless or arrogant release of the Canadian subspecies was an overt violation of the Endangered Species Act.

By reference here, I incorporate the entirety of Yellowstone Wolves by Cat Ubrikit.

These reasons and those submitted on March 31, 2006 are all arguments why it was a mistake for wolves in Montana to come under federal protection, why it was a mistake for Canadian wolves to be introduced into Montana, and why it is important to remove all federal protection and allow state control at the earliest possible date.


Gary Marbut
President, Montana Shooting Sports Association

3 Dec 2008, 7:55pm
by Mike

Comments regarding wolf delisting from Idaho Gov. Butch Otter and Idaho Fish and Game are [here].



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