Friday, September 21, 2012

Fish & Wildlife Says Wyoming Wolves Can Be Hunted Back to 1999 Levels

Additional Note.  For an indication of how ridiculous the idea of letting state fish and game authorities control gray wolf populations is, see the editorial of Lawrence Downs in the New York Times, December 28, 2013 ("Wolf Haters").

The U.S. Fish and Wildlife Service has issued final rules that remove the gray wolf in Wyoming from the list of endangered and threatened wildlife.  This finalizes the delisting that was proposed by the agency in 2011 and discussed in a prior blog.  According to Fish and Wildlife, “Wyoming’s gray wolf population is stable, threats are sufficiently minimized, and a post-delisting monitoring and management framework has been developed.“  The Yellowstone Experimental Population Area established in 1994 to facilitate reintroductions to the Park is also removed. 

In 1978, Fish and Wildlife classified the gray wolf (Canis lupus) as endangered at a species level throughout the coterminous 48 states and Mexico, excepting only Minnesota where the classification level was “threatened” rather than endangered.  The history of the Wyoming wolves and their various designations is replete with litigation and Congressional meddling, described in soporific detail in the preamble to the present rulemaking.  A useful timeline is posted on the website of EarthjusticeThrough it all, as discussed in another blog, Fish and Wildlife has been determinedly washing its hands of the gray wolf preservation business, presumably to free up staff and time for other bureaucratic sports. 

Approximately 250,000 comments were submitted regarding the 2011 delisting proposal, but Fish and Wildlife had little trouble ignoring almost all of them. 

Wolves Become Game Animals

Wolf Trophy Game Management Area and Yellowstone National Park
Wyoming wolves will now, according to Fish and Wildlife to “be managed as game animals year-round or protected in about 38,500 square kilometers (km2) (15,000 square miles (mi2) in the northwestern portion of the State (15.2 percent of Wyoming).”  Wolves will be designated as predatory animals everywhere else in Wyoming.  The map shows the year-round and seasonal wolf trophy management areas.  Only a small portion of the area, with a minimal wolf population, is seasonal.  Thus, wolves can now be hunted most of the time most everywhere in Wyoming.   

Wyoming has committed to maintaining a population of ten breeding pairs and at least 100 wolves in portions of Wyoming outside Yellowstone National Park and the Wind River Indian Reservation.  This apparently assumes about ten packs of ten wolves per pack since packs will generally have only one breeding pair.  Fish and Wildlife assures us:

“Wyoming intends to maintain an adequate buffer above minimum population objectives to accommodate management needs and ensure uncontrollable sources of mortality do not drop the population below this minimum population level.”

It must be doubted whether the wolves will take much comfort in such assurances.  As to how many wolves are in Yellowstone National Park, the rules release predicts there will be between 50 and 100 wolves and 5 to 10 packs, but there may only be four to six breeding pairs.  The Wind River Reservation primarily has isolated wolves than only occasionally form packs. 

Wolf Packs in Montana and Wyoming
That means that the objective is to have “at least 15 breeding pairs and at least 150 wolves statewide,” including the wolves of Yellowstone.  The objective for Montana, Idaho, and Wyoming combined is about 30 breeding pairs and at least 300 wolves in total.  Fish and Wildlife says that gene flow is expected throughout this small group, but acknowledges that this may have to be agency-managed (explained later as "moving individual wolves or their genes into the affected population segment").  The distribution of wolf packs at the end of 2011 is illustrated in the second map.

The objective provided in the rules release is less than the current population of wolves, meaning that Fish and Wildlife is content to have the current populations hunted or exterminated in significant numbers.  The current numbers are stated as follows:

“By the end of 2011, the NRM [Northern Rocky Mountain] gray wolf population included a minimum population estimate of 1,774 wolves (including at least: 653 in Montana; 746 in Idaho; 328 in Wyoming; 18 in Washington; and 29 in Oregon) in 109 breeding pairs (including at least: 39 in Montana; 40 in Idaho; 27 in Wyoming; 2 in Washington; and 1 in Oregon).”

This means that the minimum objective being stated by Fish and Wildlife could effectively roll back the wolf population to the level that existed in the area around 1999 or 2000, with anything above that considered a buffer.  In responding to comments to its proposed rulemaking, Fish and Wildlife says the following:

“Although population decreases are expected in Idaho, Montana, and Wyoming, we expect that these reductions will be carefully managed so that populations are maintained well above recovery levels (perhaps around 1,000 wolves will be maintained across the NRM DPS long term). Our expectation for gradual reductions was verified in 2009 and 2011 (the first 2 years of State management including a hunting season) where the population remained relatively stable (technically, slight increases were documented each year) even in the face of substantial mortality levels. Measurable declines across the region are expected to begin to occur in 2012. In Wyoming, we expect the total statewide population will be reduced between 10 to 20 percent in 2012 with continued gradual reductions thereafter, if appropriate.”

The last phrase in this paragraph, “if appropriate,” seems nonsensical.  Why would it not be appropriate if the minimum levels of animals are being left alive? 

Wolves in Idaho, Montana, and Wyoming from 1980 to 2011
It is difficult to understand how such numbers—even assuming that the minimum numbers will for some time stay below actual numbers—can satisfy anyone that the population is sufficiently stable that the wolf can be labeled a game animal. Wayne and Hedrick (2011) asked "what will happen if western states allow the population to be hunted to the federal minimum requirement for recovery ...?  Such small populations would also be more vulnerable to random demographical and genetic affects and could sink far below the minimum numbers." Wayne, R., and Hedrick, P. (2011). Genetics and Wolf Conservation in the American West: Lessons and Challenges.  Heredity, 107, 16-19. DOI:10.1038/hdy.2010.147.  

Fish and Wildlife praises Wyoming’s decision to recognize that wolves in most trophy areas could never be considered predatory animals.  In other words, Wyoming has evolved from saying that you could sometimes shoot a wolf in the trophy area as a predator to saying that you need a hunting license to shoot a wolf in a trophy area.  This, according to Fish and Wildlife, is “a substantial improvement over current Wyoming law.”  Many more such improvements will probably make wolves extinct. (Hunting wolves in the European tradition was always intended to eliminate a competing predator, though ritual elements entered into hunting and capturing of wolves by North American Native Americans.  It is safe to say that for most of the hunters who will be bagging wolves in the trophy areas of Wyoming, this is target practice.)

How Wolves Will Be Hunted

Gray Wolf Hunt Areas Established by the Wyoming Game and Fish Department
To understand how Wyoming’s idea of conservation will actually work, one must look at materials on the website of the Wyoming Game and Fish Department (WGFD).  WGFD has established 12 hunt areas, as shown by the red lines on its map.  For each hunt area, there is a season, as indicated on the table of season dates provided in a brochure issued by WGFD.  For all but Hunt Area 12, the hunting season is from October 1 to December 31. 

Each hunt area has a mortality quota, ranging from 1 to 8, totaling 52 possible kills per year. See the table below.  If the mortality quota for a hunt area is reached before December 31, the hunting season closes in that area.  The regulations require that prior to hunting, “it is the hunter’s responsibility to confirm the hunt area the person intends to hunt is open.  The status of hunt area closures shall be available twenty-four (24) hours a day by calling toll-free 1-800-264-1280.” 

Gray wolves are to be taken only with firearms and archery equipment from a half hour before sunrise to a half hour after sunset.  It is illegal to take a gray wolf by using radio tracking equipment.  According to the Fish and Wildlife release, approximately 2,000 wolves in Idaho, Montana, and Wyoming have been radio-collared at one time or another, so presumably Wyoming is hoping that hunters won’t obtain equipment that can tap into the frequencies of the wolf collars.  Wyoming has begun putting radio collars on wolves in order to verify numbers. 

Each hunter is limited to one gray wolf per calendar year.  That applies, of course, to hunting of wolves, not to the elimination of wolves classified as predators.  Use of aircraft in hunting trophy animals is prohibited, though they may be used to pursue wolves in areas where they are deemed predators. 

Trophy wolf pelts are to be turned in for registration purposes:

“Hunters taking a gray wolf in the hunt areas … shall retain the pelt and skull from each gray wolf for registration purposes. Even if the skull is damaged, it shall accompany the pelt for registration purposes. Visible external evidence of sex shall remain naturally attached to the pelt. The pelt and skull shall be presented in an unfrozen condition to allow collection of biological samples and to determine the age and sex of the gray wolf.”

Hunt Seasons by Area. Section 4(i) provides that gray wolf hunting is closed in that part of Area 6 in the John D. Rockefeller Jr. Memorial Parkway.  Section 4(j) explains that in Section 12, gray wolfes are predators from March 1 to October 14.
The hunter is to call a toll-free number within 24 hours of taking a gray wolf and report where the kill occurred. Reporting is required of wolves taken as predators as well.  The pelt is to be turned in within five days, though this is not required if a wolf is taken in an area where it is deemed predatory. WGFD nevertheless encourages turning in predatory wolf pelts “to aid the department efforts to monitor wolf populations and genetic interchange throughout the state.” If the wolf was wearing an electronic device, that is also to be turned in, presumably to be worn by some other unlucky wolf. 

For Hunt Area 12, wolves are game animals from October 15 through the last day of February, though the hunting season ends on December 31.  They are predatory animals from March 1 through October 14.  No license is needed in the predatory period. It will be interesting to see how long wolves can be found in Hunt Area 12. I suggest that any documentary filmmaker pursuing this story focus on Area 12. 

Purchasing a gray wolf hunting license costs a resident of Wyoming $18, but a nonresident $180.  A conservation stamp costing $12.50 must also be purchased.  A nonresident cannot hunt a trophy game animal “unless accompanied by a licensed professional guide or a resident guide.” It is apparent that Wyoming does not even see allowing the hunting of wolves as a way of raising cash. 

Safe Areas

Hunting is prohibited in the Grand Teton National Park, but the preamble points out that most wolves that spend time in that park also spend time in areas near it where hunting will be permitted.  Apparently most wolves in Yellowstone National Park spend most of their time inside it, so they will at least have some peace as long as they remain conscious of Park boundaries.  The Forest Service has lands in Wyoming and other states with wolf populations, but the Forest Service “typically defers to States on hunting decisions.”  Thus, State-authorized hunting occurs in National Forests, Wilderness Areas, Wilderness Study Areas, and Bureau of Land Management lands. 


With these final rules, the Fish and Wildlife Service continues its theme-park approach to environmental conservation. It also continues to follow an agenda sympathetic to those political forces that always clamor for less regulation of anything for any reason.  Although this might sound like the beginning of a diatribe against Republicans, it is to be noted that much of the delisting activity is occurring under a Democratic administration. 

Fortunately for the wolves, environmental groups have lawyers and money and, according to news reports, a coalition of them is preparing a lawsuit.  The courts have helped the wolves before, when the Fish and Wildlife Service would not, and those of us who value these beleaguered ancestors of our dogs must hope they will do so again. 

Department of the Interior, Fish and Wildlife Service, Removal of the Gray Wolf in Wyoming From the Federal List of Endangered and Threatened Wildlife and Removal of the Wyoming Wolf Population’s Status as an Experimental Population,  77 Fed. Reg. 55530 (September 10, 2012)

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