Less than a week after the Federal Government handed over wolf management to Idaho, the state announced plans to kill 75% of wolves within the Clearwater area. They are blaming wolves for decades of serious habitat problems, which lowers huntable elk numbers.

The science is flawed. These wolves do not need to die.

The official comment period is now over. This issue is far from resolved. Even if IDFG decides to kill the wolves, the U.S. Fish and Wildlife Service must approve and act upon the plan.

During the public comments period, WWP and its members stepped up to the plate, making comments and working with other non-profit groups to save the Clearwater wolves. The comment letter from WWP to Idaho Fish and Game follows.

Jim Unsworth, Steve Nadeau
Idaho Department Of Fish And Game
Boise, Idaho

Jim and Steve: This email constitutes the comments of Western Watersheds Project (WWP) on the proposed killing of 43 wolves in the Lolo area of northern Idaho. WWP is a non-profit conservation organization with 1,500 members dedicated to the protection and restoration of western watersheds and wildlife. WWP is headquartered in Hailey, Idaho with offices in Boise, Idaho and three other states.

General Comments:

1. The Decision Has Already Been Made.

These comments will be brief because WWP is of the opinion that the Idaho Department of Fish and Game (IDFG) and the IDFG Commission has, unfortunately, already made up its mind to authorize this killing of wolves, and the review of public comment is merely perfunctory in nature and will not affect the pre-ordained decision. WWP believes that the proposed decision is clearly a political decision and that IDFG is using incomplete and inadequate science to support a preconceived outcome.

2. The Role of the United States Fish and Wildlife Service To Comply With The 10J Rule and The National Environmental Policy Act.

When, as WWP expects, the IDFG Commission has authorized the killing of wolves, WWP will devote considerable effort toward convincing the U.S. Fish and Wildlife Service (FWS) to deny the request from IDFG based on violations of the 10J Rule and inadequate scientific information to support that wolves are a significant factor in the decline of the Units 10 and 12 elk herds. Additional efforts will be made by WWP to inform and ask USFWS to carry out a full NEPA review, including extensive public involvement in scoping and development of alternatives available to FWS, before making any decision to support or deny the proposed wolf killing by IDFG.

Specific Comments

After reviewing the IDFG study projecting and modeling wolf impacts on elk populations in the Lolo game units and the two peer review responses to the study that have been made available to WWP, WWP concludes that there are sufficient scientific inadequacies in the study to warrant delaying or denying the proposal to kill 43 wolves. Perhaps the most egregious of these is the failure to model changes in elk habitat conditions that have been ongoing for decades before wolves returned to the Clearwater watershed and the effect on elk populations of those manifest changes in elk habitat conditions in the areas studied. In order not to waste time by repeating other comments, WWP refers the Department and the Commission to the excellent comments on the scientific basis of the proposed wolf killing that have been submitted by Defenders of Wildlife (and incorporated here by reference) as well as the two peer reviews WWP has received. All three of these commentaries bring into questions assumptions upon which the study is based and question the conclusions in regard to the impacts of wolves on elk populations in the study area.

IDFG has failed to consider whether its objectives for elk populations in the Lolo and Clearwater areas are unrealistic and unattainable because of changes in habitat caused by regrowth of the Clearwater watershed forest lands after early 20th century wildfires, subsequent suppression of fires, noxious weed invasion and antlerless elk permits increased by IDFG in these areas in the late 1990s.

Conclusion

WWP regrets that IDFG is choosing a political response to kill wolves when the decline in elk numbers in the Clearwater area has been underway for decades prior to wolf restoration and recovery. Rather than choosing to kill native predators in wholesale numbers to satisfy a confused idea about how many elk can be sustained in the Clearwater River watershed, IDFG should consider more benign alternatives like acknowledging that objectives for elk populations in the Clearwater River watershed are set at an unreachable level even if wolves were to be completely eradicated from the area one more time.

WWP recommends that the proposal to kill wolves in the Lolo area be withdrawn.

Please keep WWP informed of this process as it it continues, and thanks for the opportunity to comment.

Sincerely,
Jon Marvel
Executive Director
Western Watersheds Project.