16 Jan 2009, 11:48am
Bears Birds Deer, Elk, Bison Wolves
by admin

Idaho Needs To Take Control of Wolf Management

by Tony Mayer, Save Our Elk [here]

Several of us from our concerned citizens group had a meeting yesterday to discuss proposed wolf legislation in Idaho. In our meeting the proposed rule change IDAPA - Idaho Fish and Game was discussed. Our group is unanimously opposed to this rule change and recommends that this proposal be tabled or killed. Below is a summary of some of our concerns:



DOCKET NO. 13-0108-0801

DESCRIPTIVE SUMMARY: The following is a nontechnical explanation of the substance and purpose of the proposed rulemaking: The Wolf Management Plan calls for maintaining viable wolf populations at or near current levels of 500-700 wolves. The proposed rules allow hunting of wolves pursuant to seasons set by the Commission.

FEE SUMMARY: Pursuant to Section 67-5226(2), the Governor has found that the fee or charge being imposed or increased is justified and necessary to avoid immediate danger and the fee is described herein.

Concern #1. The 500-700 wolves is a complete departure from the 100 wolf minimum and 150 wolf objective and from the Wolf Policy outlined in the WCMP. Further, because the IDFG “population plan” did not follow the Idaho Wolf Conservation and Management Plan (see pages 4, 5, 18, 22, and 24 here) nor is it a lawfully amended version of that plan approved by the Legislature, this language should not be approved as part of a Permanent Rule and the Idaho Legislature should instruct the F&G Commission to repeal the plan and rewrite it in accordance with I.C. Sec. 36-715.

Concern #2. The imposition of more stringent fair chase standards and/or weapon restrictions for wolves than for other predators classified as either big game or furbearers will make them more difficult to hunt and harvest. For example, bears and lions may be hunted with hounds, bears may be hunted over bait, and lions may be killed using .22 caliber rimfire ammunition, and using electronic calls in specific locations, but none of these are legal in hunting wolves according to the rule changes.

Concern #3. In 2005, HB 132 amended I.C. Sec. 36-201 “Fish and Game Commission Authorized to Classify Wildlife” by adding the following: “Notwithstanding the classification assigned to wolves, all methods of take including, but not limited to, all methods utilized by the United States Fish and Wildlife Service and the USDA Wildlife Services, shall be authorized for the management of wolves in accordance with existing laws or approved management plans.” Yet, also in 2005, the IDFG Commission Rule classifying the Gray Wolf as a Game Animal was approved as IDAPA Rule; and IDAPA Rule prohibits the use of any net, snare, trap, chemical, deadfall or device other than legal firearm, archery or muzzleloader equipment to take a big game animal. This error should be corrected.

The Rules Subcommittee needs to address these concerns and correct the discrepancies between what the law says and what IDFG has done. In addition:

1) The legislature has approved the 2002 WMP which designates an allowable population of 150 wolves in the state of Idaho. This is the law of the land. Changing the allowable level to 500-700 wolves is simply moving the goalpost with no guarantee that wolves will remain delisted. In future inevitable lawsuits, 700 wolves will become the minimum level. This unduly compromises our state’s position in future negotiations without any assurances from the other side that wolves will remain delisted. We simply will have moved the goalpost and can only go up further from there.

2) Earth Justice maintains that significant scientific basis exists for a minimum viable population of 5000 wolves in the region for wolves to be recovered. Idaho will bear the brunt of this level, conceivably requiring an eventual MVP for Idaho of 2,000 to 3,000 wolves for them to be satisfied. By continuing to move this “goalpost” we are playing right into their hands. They are already on record that they will challenge this delisting proclamation and the lawsuits will not stop until they get what they want. All they have to do is find a sympathetic district judge and we are back to ground zero with delisting. Further, Ed Bangs makes the point several times that the new Obama administration can easily change the wolf delisting status with the stroke of a pen. Giving up this ground and agreeing to 700 wolves is a huge mistake. Our state will give up our bargaining position from which we will never be able to recover in future negotiations.

3) To our knowledge, the IDFG has not performed studies justifying the acceptability of this level of wolves, nor has the USFW updated the original EIS for the impacts of this level, or the current level of wolves. This is a direct violation of the NEPA requirements of the EIS. From the sportsmans’ standpoint, we have seen no evidence that our states elk population will support a MVP level of 700 wolves; in fact the evidence suggests supporting this level of wolves will result in significant depredation of elk.

You can argue with these numbers and assumptions, however generally you would have to agree that they are in the ballpark. If you start with a elk population of around 100,000 in Idaho reproducing (net of natural mortality) at around 5 to 10% annually. (A further note - elk reproduction is being deterred and diminished by constant harassment from wolves.) It is generally proven that wolves consume 1.8 to 2 elk per month. Therefore on average we will assume each wolf kills 2 elk per month. At a population of 700 wolves, they will kill around 17,000 elk per year, with the majority of the kills (70%) yearling and cow elk. If you allow for a hunter average take of 10,000 to 20,000 per year, the resulting numbers spell pending disaster for our elk population!

Below are some rough calculations which indicate significant depredation will result.

Year 1. 100,000 x 1.1 = 110,000 elk - 17,000 wolf kill - 15,000 hunter take = 78000 elk

Year 2. 78,000 x 1.1 = 85,800 elk - 17,000 wolf kill - 12,000 hunter take = 56,800 elk.

Year 3. 56,800 x 1.1 = 62,400 elk - 17,000 wolf kill - 10,000 hunter take = 29,800 elk.

Even if one argues that these elk kill numbers are high, they are still in the ballpark. It is undeniable that our elk population cannot possibly tolerate this level of depredation by wolves. This concern is even more alarming as Idaho currently has far more than 700 wolves, consuming even more elk then estimated. Further, considering that wolves are expanding at an annual rate if 20-25%; and considering that wolves are next to impossible to manage and control by hunting alone, we are in very serious trouble.

Regardless of the opinions of some and the argument that the allowable level must be raised to 700 wolves, with the threat “do it or risk re-listing,” we cannot afford to fall for this argument and to fall into this trap. All the concessions made in the past have not worked and neither will this concession. Our position is that Idaho must remain firm and not allow any variation to the 2002 and 2008 approved Wolf Management Plans. If our states position on wolves changes and we cave on the numbers, we are spelling disaster for our future elk herd.

Save Our Elk is currently drafting coordinated wolf legislation along with Montana and Wyoming. We believe this approach is the only feasible long term solution to effectively deal with this wolf problem. The proposed legislation is similar for all 3 states and is broad and comprehensive in dealing with the wolf issue; it puts the interests of hunters and citizens first, and includes the Commerce Clause along with asserting 10th Amendment states rights. We believe only with a coordinated multi-state effort will we be able to take control of this issue and move it back in our favor of our state for us to manage.

18 Jan 2009, 1:21pm
by George

The first (and only) delisting proclamation was published by USFWS/DOI in the Federal Register / Vol. 73, No. 39 / Wednesday, February 27, 2008 [here].

That was a week before the IDFG plan was passed by the IDFG Commission and therefore was not and could not have been “approved” by the USFWS as a condition of the first (and only) delisting published thus far. The “Information Quality Act Disclaimer” of March 7, 2008 [here] was simply acknowledgment of the receipt of the plan and included its standard disclaimer statement. I am not aware of any document indicating that USFWS approved the IDFG Wolf Management Plan or even recognized anything but receiving it until the July 2008 Court decision.

However, it was of course recognized in the Dec. 11, 2008 re-listing notification published in the Federal Register thanks to the recent letter jointly signed by IDFG and the Idaho Governor’s Office of Species Conservation. Like the change to managing for 500+ wolves, that letter was submitted without authorization by the Idaho Legislature.



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