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Last chance to have your voice heard on Wyomings’ wolf delisting plan

Comments to the U.S. Fish and Wildlife Service regarding Wyoming’s wolf delisting plan MUST be received within a 100 days on or before January 13, 2012.  This is our last chance to be heard regarding this plan.  I sent a letter to Wyoming Game and Fish before the comment closing date which was on a Thursday.  The following tuesday they announced their acceptance of the plan.  Had they read my comments?  I doubt they were reading over the weekend.

But these are the Feds and the ones who have initiated the deal and done the science.  The more comments, maybe we can actually hold them to the science instead of the back door political deal Secretary of the Interior Ken Salazar maneuvered with Wyoming Governor Matt Mead.

Folks,  wolves do not belong to Wyoming and Wyoming politics.  Wolf recovery and management shouldn’t be based on the demands of the Elk Foundation, the NRA, or the Safari Club International.

In the USF&W website maze, I found it hard to locate the information as to where to send comments so I will print it here.  I am also copying an attachment from a letter from the Sierra Club Resilient Habitat department regarding talking points you might include in your letter.  Please take a moment and have your voices heard.  Thank you.

A majestic predator that deserves to take its place in the ecosystem

Tell the U.S. Fish and Wildlife Service (USFWS) that its draft rule to delist wolves in Wyoming is flawed and should be withdrawn. Submit your comment today!


Written comments can be submitted by one of the following methods:

1) Federal eRulemaking Portal: http://www.regulations.gov. Enter “FWS-R6-ES-2011-0039” in the “Keyword” box and check “Proposed Rule” in the “Document Type” box.

2) U.S. mail or hand-delivery: Public Comments Processing, Attn: Docket No. [FWS–R6–ES–2011–0039]; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042-PDM; Arlington, VA 22203.


Consider making the following points in your comments:

  • This plan is virtually identical to multiple plans that have been rejected previously by both USFWS and federal courts because of their unacceptable impacts to wolves and the lack of regulatory mechanisms to conserve wolves as required by the Endangered Species Act.
  • Wolves should be managed by the Wyoming Game and Fish Department across the entire state, not as “predator” in 88% of the state (where they can be killed by any means by anyone, without a license) and “trophy game” in an arbitrary zone around the national parks. No unregulated killing of wolves should be allowed.
  • The proposed “flex-zone” area south of Grand Teton National Park is not grounded in sound science. The USFWS has arbitrarily drawn this line where wolves will receive limited protection as ‘trophy game” for only 4 months of the year. The USFWS admits that this will only likely protect half of the seasonal dispersal of wolves and that only 35% of dispersing wolves will probably reproduce. This proposed zone will almost certainly not protect effective dispersal because wolves will be hunted during the period of protection and very likely be eradicated (through unlicensed killing) from the area for the remaining 8 months of the year.
  • The USFWS will allow Wyoming to define “unacceptable impacts” of wolves on elk and other ungulates (which will almost certainly result in wolves being killed), yet Wyoming’s plan has not defined any criteria for determining “unacceptable impacts” by wolves. Currently, all of Wyoming’s 35 elk management units are at or above the Wyoming Game and Fish Department’s numeric objectives for those herds.
  • The USFWS disingenuously concludes that the Wyoming dual classification (trophy game/predator) plan is biologically sound because the remainder of the state is unsuitable wolf habitat. However, the proposed predator zone has contributed 3 breeding pairs, and 6 of the state’s 30 packs have entire or partial territories within this zone.
  • Relying on the indiscriminate shooting of wolves as the primary management tool to reduce wolf conflicts is not a strategy for success. Wyoming should work with stakeholders to promote tolerance and prevent conflict by implementing nonlethal, proactive wolf deterrents and livestock husbandry practices. There are active and successful programs working with ranchers and wolf managers in other states and this could be expanded to Wyoming if state and federal agencies are willing to work collaboratively and support these management tools.
  • Wolves play a key role in maintaining a healthy ecosystem. Since wolves were reintroduced to Yellowstone, beavers, songbirds and many other species are making a comeback. These benefits must be recognized in any management plan.
  • Millions of people come to Wyoming every year for the chance to see a wolf in the wild. Wolves in Yellowstone alone generate an estimated $70 million annually in cumulative impacts from wildlife viewing.