…Include in your comments information from scientific journals and or from best available scientific data. In other words, submissions merely stating support for, or opposition to, the action under consideration without providing supporting information, although noted, will not meet the standard of best available scientific and commercial data.
Read further to find links to articles that support your comments.
A Proposed Rule by the Fish and Wildlife Service on 03/15/2019 We will accept comments received or postmarked on or before May 14, 2019.
Gray wolf advocates request public hearings, in writing, at the address shown by April 29, 2019: Don Morgan, Chief, Branch of Delisting and Foreign Species, Ecological Services, U.S. Fish and Wildlife Service, Headquarters Office, MS: ES, 5275 Leesburg Pike, Falls Church, VA 22041-3803; telephone (703) 358-2444. Persons who use a telecommunications device for the deaf (TDD) may call the Federal Relay Service at 800-877-8339.
We (Fish and Wildlife Service, Interior) intend that any final action resulting from this proposal will be based on the best scientific and commercial data available and will be as accurate and as effective as possible. Therefore, we request comments or information from the public, concerned Tribal and governmental agencies, the scientific community, industry, or any other interested parties concerning this proposed rule. Comments should be as specific as possible.
As this proposal replaces our June 13, 2013, proposal to delist gray wolves in the lower 48 United States and Mexico (78 FR 35663), we ask that any comments previously submitted that are relevant to the status of wolves currently listed in the contiguous United States and Mexico, as analyzed in this rule, be resubmitted at this time. Comments must be submitted during the comment period for this proposed rule to be considered.
Please include sufficient information with your submission (such as scientific journal articles or other publications) to allow us to verify any scientific or commercial information you include.
The following are links to articles that support your comments.
In the United States, data show that wolves (Canis lupus, Canis lupus baileiy and Canis rufus) kill few cattle and sheep. (click on the highlighted words to view scientific data)
Killing wolves to prevent predation on livestock may protect one farm but harm neighbors (click on the highlighted words to view scientific data)
Please note that submissions merely stating support for, or opposition to, the action under consideration without providing supporting information, although noted, will not meet the standard of best available scientific and commercial data. Section 4(b)(1)(A) of the Act directs that determinations as to whether any species is threatened or endangered must be made “solely on the basis of the best scientific and commercial data available.
You may submit comments by one of the following methods:
(1) Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov. In the Search box, enter Docket No. FWS-HQ-ES-2018-0097, which is the docket number for this rulemaking. Then, click on the Search button. On the resulting page, in the Search panel on the left side of the screen under the Document Type heading, click on the Proposed Rules link to locate this document. You may submit a comment by clicking on the blue “Comment Now!” box. If your comments will fit in the provided comment box, please use this feature of http://www.regulations.gov, as it is most compatible with our comment review procedures. If you attach your comments as a separate document, our preferred file format is Microsoft Word. If you attach multiple comments (such as form letters), our preferred format is a spreadsheet in Microsoft Excel.
(2) By hard copy: Submit by U.S. mail or hand-delivery to: Public Comments Processing, Attn: Docket No. FWS-HQ-ES-2018-0097; U.S. Fish & Wildlife Service Headquarters, MS: BPHC, 5275 Leesburg Pike, Falls Church, VA 22041-3803.
We request that you send comments only by the methods described above. We will post all comments on http://www.regulations.gov. This generally means that we will post any personal information you provide us (see Public Comments below for more information).
Is Wisconsin’s management of wolves responsible?
A good case study for state management is Wisconsin between 2012 – 2014. In those two years 528 wolves were legally killed. These harvests aren’t based on science and often hurt wolf populations by breaking up packs and orphaning young. Yet these forms of management are still considered standard practice for state wildlife agencies.
Beyond highlighting unethical management practices, the workshop drove home a constant theme – wolves are not the monsters we make them out to be. A lot of our fears about wolves are based on anachronist folklore that has no place in the 21stcentury. For instance, far from being rapacious killers who deplete game populations, wolves actually help keep herds healthy by preying on the sick, the old, and the weak. A graph documenting wolf predation reflected this, with the ages of kills being mostly very old and very young. Also, the impact on livestock is overblown. Of Wisconsin’s 1.5 million dairy cows and beef cattle, the WDNR confirmed 24 wolf kills in 2018.
The hysteria around wolves is largely pushed by farmers and hunters who loathe predators – wolves, coyotes, bears, lions – and that’s terrible for conservation efforts. These two groups pump millions of dollars into state wildlife management through hunting and trapping licenses, and hunting related sales taxes. This has lead to a prioritization of policies that favor these two groups at the expense of non-game species.
Out of all the states that hunt wolves, only Wisconsin allows hound hunters to use unleashed packs of dogs to hunt wolves. Wisconsin, quite literally, throws “dogs to the wolves.”Hound hunters traditionally train their dogs to focus on specific prey by releasing their dogs to surround, attack and terrorize a prey animal (e.g. a bear cub or fox) for hours on end (up to 16 hours/day) enclosed in a small, open barrel or “roll cage.” At this point it remains disturbingly unclear as to how hound hunters will train their dogs to pursue wolves instead of other animals—will it be by capturing wolves and allowing their dogs to attack them in barrels and pens? How isn’t this worse than illegal dog fighting?
During the 2016 Wisconsin bear hunting season 37 hunting dogs were lost in the pursuit of bear. A few Wisconsin legislators claim these deaths were due to the high wolf population of 866 in 2016, but there’s a whole lot more to this story than meets the eye. Adrian Wydeven, former Wisconsin DNR Head Wolf biologist, wrote in a opinion editorial, “Numbers don’t add up in wolf-hound debate” written on November 12, 2016 and suggested that:
“Do wolf numbers correlate with wolves killing hounds? The evidence suggests this might not necessarily be the case. In 2012, only seven dogs were killed and yet there were nearly as many wolves in 2012 as there were in 2016 (815 wolves in late winter 2012).” Source
There were 52 wolf depredations from April 15, 2016 through April 15, 2016. To put it in perspective, that was 52 livestock deaths by wolves out of 3.50 million head of livestock in Wisconsin. Read for yourself:
“The total inventory of cattle and calves on January 1 rose 3 percent from 2014 to 2015, to 3.50 million head. The number of milk cows rose by 5,000 head to 1,275,000 head and the number of beef cows rose 25,000 head to 275,000 head. On the U.S. level, slaughter prices rose to $153.00 per cwt. for cattle and $255.00 per cwt. for calves. As a result, Wisconsin’s value of production rose 33 percent to $1.92 billion.” Source: USDA Wisconsin statistics
Wisconsin’s Record On Wolf Management
Wisconsin became the only state to allow hound hunters to use unleashed packs of dogs to hunt wolves. Wisconsin, quite literally, throws “dogs to wolves in two of the three wolf hunts in 2013 & 2014. Wisconsin hunters killed 528 wolves in the three seasons a hunt was held in the state before the animal was placed back on the endangered species list.
The Gray Wolf Monitoring Report done through the Wisconsin Department of Natural Resources and can be found on their website estimates 905-944 wolves reside in Wisconsin’s northern & central forests.
Livestock depredations included 29 cattle killed and 1 injured, and 4 sheep killed. The number of farms affected was the same as the previous monitoring year. That number doesn’t include depredations of hunting dogs.
In wolf management units 1, 2, and 5, considered to be primary wolf range and containing 80% of the minimum winter wolf count, deer density estimates increased 19% compared to 2016.
The U.S. Fish and Wildlife Service (USFWS) plans to propose a rule to “delist” the gray wolf from the endangered species list in the Lower 48 states. USF&WS is required to hold a public comment period on this ruling. This comment period is now open.
If delisting does occur in Wisconsin, my hope is that with the new WDNR Secretary in place, the required wolf management plan will include greater transparency allowing for public input in how the Gray wolf is managed. And that the public will speak up against a trophy hunt on gray wolves.
There hasn’t been a wolf hunt since 2014. The Gray wolf is thriving on Wisconsin’s landscape, the wolf population is exhibiting signs of self-regulating, Gray wolves and White-tailed deer are benefiting each other once again, and livestock depredations aren’t a major threat.
A Proposed Rule by the Fish and Wildlife Service on 03/15/2019 We will accept comments received or postmarked on or before May 14, 2019. Take Action to protect Gray wolves & Wisconsin and across the U.S.!