Wolf Ranch Foundation
Comments on Idaho Fish and Game Proposed
Removal of Wolves from GMU 10, 12, 17
February 13, 2006
Prepared by Michael Wolf
Director, Wolf Ranch Foundation
Summary:
The proposal in question was prepared by
an organization biased towards hunting in
a state with an official position which to
this day calls for the removal of wolves
and merely accepts management as a necessity.
The proposal is fraught with errors and omissions
and results in data which do not support
the conclusions made. It is the belief of
Wolf Ranch Foundation that this proposal
should not be considered as its conclusions
are not accurate based on the data within
and especially in light of missing data.
Background:
Since wolf reintroduction in 1995 and 1996
to Idaho; wolves have been actively persecuted
in the State of Idaho. This attitude has
taken an official form by the
State of Idaho in the form of Idaho Joint
Memorial Resolution 5 of 2001 and Idaho House
Bill 294 of 2003. These official representations
of State attitudes
towards wolves remain unchanged to this day.
The state officially still maintains a policy
statement that wolves are to be removed from
the state of Idaho through
all means necessary.
This Idaho Fish and Game (IDFG) proposal
in our opinion is influenced by and reflects
this official state attitude. Further, the
attitude of Steve Nedeau of IDFG, is
one of zealous anticipation for opening up
hunting of wolves in the State of Idaho.
His enthusiasm was witnessed by the director
of Wolf Ranch Foundation at a
seminar on wolf reintroduction and management
in Idaho held at the University of Idaho
in Fall of 2004.
It is the belief of Wolf Ranch Foundation
then that incredible bias is held by IDFG
to remove wolves, to kill wolves through
any means possible, including using
purposefully or incidental bias in reports
such as this one being commented on.
With bias having been established as a potential
factor skewing the results of the report
in question; the report itself will be judged
in and of its own merit; with
the underlying belief that the errors in
the report may be a result of either policy,
active skewing of data, or pure bias in findings
and data. Whether this bias is
intended or not; it is the belief of Wolf
Ranch Foundation that until Idaho rescinds
JMR005 and H0294 language which puts wolves
on the political chopping
block, that IDFG cannot be trusted to create
a proposal that uses unbiased scientifically
sound data to conclude anything that legitimately
puts forth factual
issues regarding wolves as having a negative
impact in the State of Idaho.
Wolf Ranch Foundation is not opposed to management
of wolves. But we are opposed to mismanagement
of wolves. We believe that data showing wolves
are having a severe effect on elk population
should be sound data, free of bias, and without
question show that elk are being prevented
from recovery by wolves and wolves alone.
If the proposed removal were to take place,
and the decline of elk continue; IDFG would
be proven wrong; but only after the unnecessary
removal of wolves. We believe that this mistake
cannot be afforded.
Further, IDFG's own documentation indicates
that a great impact on elk populations was
realized in 1971 when Dworshack Reservoir
was created. This meant the loss of extensive
winter habitat for elk. This proposal does
not include any language to this effect,
nor does it suggest correcting this loss
of habitat as a management tool.
Detailed Comments on Proposal:
"Data that demonstrate the impact of
wolf predation."
The data used to evaluate populations does
not provide an accurate representation of
wolf impact, especially since such data were
not taken (or were not
presented) which does a direct comparison
to numbers before wolves were introduced.
Collared elk studies were not done prior
to the appearance of wolves in
GMU 10, 12, and 17.
Further, data were missing with regards to
the health of animals. Hunters do not generally
kill sick or injured elk. These elk are the
primary targets of wolves. This is documented
fact. Yet the data for the health of the
elk killed by wolves does not include even
a cursory summary of health.
Still further, the simulations mentioned
were not set forth as including data paramount
to making such a claim. Simulation models
must account for all factors; including current
rates of decline due to factors such as other
predators, hunting, and especially habitat
loss. The claim that wolves are the limiting
factor can therefore be made for any factor
including other predators, hunting, and habitat
loss.
"Why wolf removal is warranted."
This section makes assumptions based on bad
and missing data, and shows bias. Data do
not support the assumption made in this paragraph.
The following statement is made in the proposal:
"A reduction in wolf numbers in the
Lolo Zone should be accomplished through
regulated take by sportsmen." This statement
reflects the enthusiasm of Steve Nedeau as
witnessed previously and demonstrates that
IDFG is willing to use any means possible
to enact its agenda and that of the State
of Idaho. This proposal was limited in scope
to removal of wolves. Why then is the means
of removal specified? Removal should take
place through normal management means; not
through open hunting which could have effects
that would place livestock operators in jeopardy
by upsetting wolf pack status and driving
wolves to take whatever they can find. This
is due to wolf pack structure. USFWS 10j
rule does not authorize game hunting of wolves;
but provides for management as a tool. Because
elk, a herd animal, are managed by game hunting
does not mean that such a management tool
of wolves can or will be successful or have
effects. No data exist on this practice where
livestock are involved. Does the State of
Idaho wish to conduct experiments? Why isn't
normal management practice being suggested
here? It is the belief of Wolf Ranch Foundation
that the reason is clear: bias towards accomplishment
of IDFG's goal of open hunting on wolves
for profit to be had by IDFG in the form
of tags for wolves.
Public Involvement
The Clearwater Elk Initiative was not a legal
organization; nor is it an organization with
an unbiased agenda. This organization cannot
provide unbiased data or recommendations
due to its method of formation. It was formed
with a single agenda in mind and therefore
cannot be trusted to provide unbiased data.
Yet IDFG used the recommendations of this
private (not public) group in their report.
This is a clear violation of ethics.
Further comments:
Data presented in the form of figures clearly
shows a trend that is not affected by wolves.
In figures 1 and 2 especially, a trend can
be followed that gives no evidence of a change
related to the presence of wolves. Further,
figure 5 seems to belie IDFGs assumptions
by showing that an extremely large number
of hunter permits were issued 1 and 2 years
before wolf reintroduction. This would seem
to provide factual evidence as to a decrease
in population following this increase in
hunter take.
Conclusions:
It is the conclusion of Wolf Ranch Foundation
in examining this IDFG proposal to remove
wolves from GMUs 10, 12, and 17 that IDFG
not only failed to provide evidence within
the proposal as presented, but failed to
examine all data needed to make such assumptions,
and mishandled data such as simulations.
It is the assumption of Wolf Ranch Foundation
based on the official position towards (against)
wolves and the enthusiasm on the part of
IDFG to enact game hunting of wolves that
bias, not science, form the basis of IDFGs
arguments in this proposal.
Therefore, Wolf Ranch Foundation concludes
that this proposal should not be accepted
by the State of Idaho and should be rejected
by US Fish and Wildlife Services.