WODCW’s letter writing campaign yielded several fact filled letters urging Democratic Senator Tammy Baldwin to withdraw her support of federal delisting. Unfortunately the senator did not withdraw her support of removing the wolf from the endangered species list in the states of Wisconsin, Minnesota, Wyoming & Michigan. The federal wolf delisting action is a real possibility with this new congress. The following is one of these letters written to Senator Baldwin, read on:
Dear Senator Tammy Baldwin,
As a Wisconsin resident, I am writing to implore you to keep gray wolves listed as endangered species per the recommendations of U.S. District Judge Beryl Howell of Washington, D.C. The decision to once again delist gray wolves in Wisconsin and resume hunting and trapping should be based on science not politics.
I’ve included some of my reasons for opposing this decision as well as quotes from two of the letters that were sent on Sept. 27 2014 and October 15, 2014 to the U.S. Fish and Wildlife Service officer regarding this topic by wildlife biologist, Adrian Treves, director of the Carnivore Coexistence Lab for the UW-Madison’s Nelson Institute, B. Bergstrom, PhD, D. Parsons, MS, P. Paquet, PhD, R.P. Thiel, Certified Wildlife Biologist (Retired), and Jonathan Way, PhD. Their detailed analysis sheds light on the misleading statistics reported by Wisconsin’s Department of Natural Resources (WDNR) related to wolf hunt mortality rates; birth rates; unreported poaching; effects of year round, unregulated training of free-running dogs on wolves, night and day, year-round, with no rules or safeguards for law enforcement to implement; and inadequate recording and monitoring of wolf populations in general.
After reading the analysis of mortality levels of wolves before and after “harvest,” and reviewing the lack of adequate monitoring of populations, I am gravely concerned that delisting wolves from the endangered species list will result in severely diminished populations. In addition, the post-delisting monitoring (PDM) rules required by the Endangered Species Acts (ESA) of 1973 and published in the Federal Register require the USFWS to exert regulatory authority monitoring for not less than five years. C.M. Wooley, acting regional director for USFWS out of Minnesota, declined to implement PDM, saying, “The service no longer serves as a regulating entity to protect the wolf” nor has “a role in regulating gray wolves in any of the states of the Western Great Lakes.” This is clearly in violation of the ESA.
Other concerns regarding delisting wolves and the subsequent wolf hunts presented in the Sept. 27 and Oct.15 letters include:
The USFWS was given inaccurate and incomplete data by the Wisconsin DNR and was not able to determine wolf populations in Wisconsin.
Other factors Indicating a potential cause for concern included a significant adverse change in wolf, wolf prey, or wolf habitat management practices or protection across a substantial portion of the occupied wolf range in the Western Great Lakes wolf population. (Including Wisconsin.)
Data on successful reproduction of Wisconsin wolf packs have not been presented publicly or presented to the independent scientific community for review. These data were provided in the past, thus interannual comparisons require them. These data are essential to proper estimates of population status because substantial population declines can occur at moderate levels of mortality if reproduction is impaired.
Wisconsin did not submit all wolf carcasses for necropsy as required. … Without these data we cannot assess if poaching has risen with initiation of harvest or deregulation of hound training in Wisconsin.
On July 10,2014, the Wisconsin Court of Appeals allowed training hounds on wolves year-round, night and day, without strict regulation anywhere free-running hounds are allowed, and without safeguards for wolves or hounds. The unregulated use of this novel training method cannot guarantee the safety of wolf pups or older wolves confronted by a pack of ≥6 hounds. This activity is currently unmonitored because the timing, location, and method of hound training are not currently regulated and there are no provisions for informing law enforcement when training is underway. Both of these potential threats could be severe and could require additional regulation by the ESA as ‘”to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct’, ESA Sec. 3(19)) (Wisconsin is the only state in the US to allow dogs be used in wolf hunts.)
Facing unmonitored new threats (hound-hunting and hound-training), potential increases in an old threat (poaching), and changes in monitoring methods, we express strong scientific concerns about Wisconsin’s wolf management.
In sum, mortality data are not reported using the best available science and these data remain unclear more than 60 days after our first letter of concern and over two years after delisting. … Therefore we urge emergency relisting pending independent scientific review.
Most importantly, the wildlife biologists recommended in the Sept. 27 letter:
We recommend an independent scientific review by scientists from multiple disciplines who have peer-reviewed, scientific publications on wolf mortality, hound-hunting, or human dimensions of poaching.
The independent scientists should be chosen to avoid those with conflicts of interest or otherwise beholden to the USFWS or the WDNR. That panel should be authorized by the USFWS to inspect all data collected by the State of Wisconsin.
In other words, Senator Baldwin, in order to obtain the best available science for making decisions regarding the management of gray wolf populations in Wisconsin, it is necessary to have knowledgable scientists from multiple disciplines who are free from conflicts of interest or other political pressures making recommendations for state regulations related to wolf management.
One last issue to mention, which is also addressed by Adrian Treves, (director of the Carnivore Coexistence Lab, UW-Madison) regards the justification of a wolf hunt based on a decreasing deer population:
Although consumption of deer has increased as the wolf population has grown, wolves are not driving deer numbers down to dangerous levels,” the biologist says. The biggest factor that affects our deer herd are winters and the hunting [season] harvest.
In closing, I’ve chosen to address the issue of delisting gray wolves in Wisconsin by quoting unbiased, wildlife scientists whose analysis and recommendations were presented in two letters from September 27, 2014 and October 15, 2014 to the USFWS. Using best available science, their recommendations reflect the management strategies that were envisioned when the Endangered Species Act was first created in 1973, These scientists are not beholden to politics, gun hunting organizations or environmentalists. They have used their knowledge of wolf biology to assess our current wolf management practices, and based on that knowledge, requested the gray wolf be relisted on the endangered species list in 2014.
I am asking you, Senator Baldwin, to please consider the scientific views presented by the wildlife biologists quoted in this letter when making your decision regarding delisting. I would also encourage you to read the letters in their entirety that are attached to this email.
In addition, keep in mind that the majority of Wisconsin residents support a wolf population (2014) at least as large as the state has now, according to a survey released by the Department of Natural Resources.
Thank you for taking the time to consider my opinions that reflect the best available science-based information I’ve presented.
I’m hopeful you’ll make the right decision to keep the gray wolf on the endangered species list and work with the USFWS and the Wisconsin DNR to provide better monitoring and management practices, which will allow transparency in evaluating gray wolf populations in the future. Currently, neither organization has provided evidence they have achieved this goal.