December 12, 2009

Fellow Sportsmen, this is an SOS call for the WEST:

SFW has invested over $500,000 over the past several years to get wolves delisted - done twice - and to keep the delisted in the court room. We cannot win this fight alone, the entire hunting community needs to wake up and take this issue seriously.

I have written this email to be a little raw to stir some people to action. I am not the best at saying it all just right, but we have been in the fight, took some punches and delivered more than we take.

This issue is SERIOUS!! SERIOUS for the future of hunting elk, moose, mule deer and wild sheep in all the WEST.  In places, the game has already been lost for a generation - see below:

In the Billing Gazette the other day, (Billings, Montana), there was an article calling for a meeting to discuss the future of elk hunting in the Gallatin Valley.

Montana Game and Fish (FWP) confirmed what many of us have said for ten years:  after many years of low calf production, elk herds won't slowly decline, the will precipitously collapse.

This herd was counted at 1,500 elk in 2005 and all cow hunts were stopped. The herd has declined 85% and is now at 200 - NO, not a typo - two hundred animals!  I predict there will be less than 100 elk in that herd next year - and to even CONSIDER a HUNT of up to 450 bull elk tags, what in the - (you get the point) - can they be thinking ?

Wolves are the main culprit - recognized by Montana FWP in this article - Pro Wolf Game & Fish folks ... WAKE UP!! HERE's your sign:  address this problem or you are OUT OF A JOB!!

This is just one of many elk herds biting the dust, with Moose, deer and sheep herds soon to be going down the drain with them.

In the same paper, there was an article where the Montana FWP ordered a pack of wolves to be killed because they had killed a couple livestock and 3 guard dogs.

Wipe out a 1,500 herd of elk, do nothing? Close the Montana wolf quota season when it reached 50, not 75 as planned? But act when 3 dogs are killed? What are the people in Montana thinking? Why are the sprotsmen sitting by idly and watching it happen without lifting a finger???

I know what the sportsmen of Utah would do! Worse case, we would go to the PETA pound and save 1,000 dogs about to be killed by PETA and HSUS and stake them out in wolf areas - well fed and cared for of course - but when the wolves killed these dogs, get the wolves killed. Or we would go and buy a bunch of ba ba sheep, stake them out in five acre pens and when wolves killed them, get the wolves killed.

Or, what I really think the sportsmen of Utah would do, is let the Governor of Utah - if he still wanted to be governor, know he better take action to protect game herds and NOW!!

As this might fly around the country, that is just not idle talk. The Sportsmen of Utah stood thousands strong on the steps of the Utah Capital years ago and thankfully, Governor Leavitt and then Huntsman, took an interest in Sportsmen issues, as has Governor Herbert. Since that rally, sportsmen of Utah have continued to organize and invest hundreds of millions of dollars to increase herds, fix habitats, and control predators. We dramatically reduced lion populations; we have a state sponsored coyote control program; we made them bring our spring bear hunt back.

The various Utah sportsmen groups, SFW, MDF, SCI, NWTF, FNAWS, Trappers, etc. have worked together to tackle tough issues - together.  We changed our state constitution when experts said it couldn't be done. We took on the anti-hunting groups and pounded them into oblivion. You can too!

And it is my prediction that the Utah legislature is about to take another bold step to protect our game herds soon.

Come on Montana sportsmen, save yourselves while you still can! As soon as all the elk are gone the wolves will be down here in Utah as well.

SFW has worked hard to get the wolves delisted and has been in the courtroom from day one to KEEP wolves delisted. The least you can do is show a little fire and take care of your state, now that wolves are not an endangered species any longer!!

There ought to be 5,000 sportsmen standing outside the Missoula Court Room when Judge Malloy drives in to hear the case to keep wolves of the Endangered List. If it was in SLC, I guarantee you, that would be the case!

To sportsmen leaders around the Country - Toby Bridges has been sounding the SOS call to the hunting industry to engage in this fight. If all the sportsmen across the country don't engage and win this fight, and the anti's get their 6,000 to 8,000 wolves, hunting in the west will be only a memory of the good old days.

This issue is serious as a heart attack. Karl Malone and Jeff Foxworthy have stepped up to join the fight. George Strait, Ted Nugent, other big names who hunt the west it is time for all of you to step up too.

The anti-hunting groups are putting all their chips in on this bet, and if sportsmen don't match their bet, the game is over!

Don Peay,

SFW Founder,

Utah

Official Statement:

2009

25 November 2008

To Whom It May Concern:

On behalf of Wyoming's Sportsmen for Fish & Wildlife, the following comments are submitted pertaining to the Western Gray Wolf Delisting as requested by the United States Fish & Wildlife Service (the Service), Department of Interior.  In particular, the seven points identified by the Service are addressed.

Item 1)  It is neither appropriate nor necessary to revise the recovery goal of the Western Gray Wolf. The Service may choose to clarify that genetic exchange is not meant to be measured on an annual basis but rather tracked over time to confirm that sufficient genetic diversity persists to allow for a healthy and recovered gray wolf population. The fact that the NRM wolf population has surpassed the numerical recovery goal for 9 consecutive years should be enough to allow for the affected states to implement their biological and scientifically sound wolf management plans for this non-essential, experimental population. The Service and affected States have already demonstrated that they can in fact recover wolves. Had Judge Malloy not interfered with this process the entire Nation as well as the World could have seen that wolves can effectively be managed and maintained at recovery levels. The Service may be severely limiting itself if it so narrowly defines genetic exchange as through either natural migration or managed genetic exchange. The service should spend more time articulating the highly genetic diversity which exists in the current NRM DPS as compared to other wolf populations abroad. In addition, an indepth explanation of the inadequacies and false assumptions based upon the vonHoldt et al. (2007) study are warranted.

Item 2)  The Service should consider creating occasional disruptions of wolf pack structure or reduced wolf density in select areas of suitable and acceptable habitat to create social vacancies or space for dispersing or introduced wolves to fill. In Judge Malloy's decision he assumed that more wolves would lead to an increase in genetic exchange. If suitable and acceptable wolf habitat is already occupied and filled to capacity this is one viable option to encourage genetic exchange to occur. The Service needs to reiterate that this non-essential, experimental population of wolves was begun via an introduction. The Service should not be required to differentiate between natural migration and managed genetic exchange.

Item 3)  Wyoming has already identified what portions of their state needs to be managed as a trophy game area. The Service has already acknowledged that Wyoming's wolf management plan covers 70% of the available suitable wolf habitat. The remaining 30% of suitable wolf habitat has been excluded by the citizens of Wyoming as it is socially and economically unacceptable. The Service, through their management actions, has only reinforced and confirmed that Wyoming got it right when they designated the trophy game area. Human-wolf conflicts are too high in the predator zone as your actions have shown. In addition, Wyoming has already held numerous public meetings to address this topic and it is inappropriate for the Service to circumvent this long accepted and established process. While some, including Judge Malloy, may not like Wyoming's wolf management plan 10 out of 11 wolf experts chosen by the Service have stated that Wyoming's plan in concert with Idaho and Montana is scientifically and biologically sound. Since their review and at the request of the Service, Wyoming's 2003 wolf management plan, which was overwhelmingly approved by these National wolf experts, was changed in 2007. Those changes increased the size of Wyoming's trophy game area to maintain the viability of the NRM DPS. No additional changes are necessary or warranted.

Item 4)  All three States including Wyoming have committed to maintaining 15 breeding pairs and a minimum mid-winter population of at least 150 wolves. This non-essential, experimental population of wolves has been recovered for 9 years. One way in which malleable is defined is having a capacity for adaptive change, from Merriam-Webster dictionary. Adaptive wildlife management is not a new concept. Judge Malloy used the term malleable; however, adaptive wildlife management practices are being implemented by state agencies across the Nation. Why should Wyoming be any different? Wyoming's application of adaptive wildlife management techniques applies the most current and most accepted use of science to determine what specific actions are required in order to obtain a specific outcome. The malleability of their trophy game area doesn't affect their ability to manage for stated wolf objectives. In fact, their adaptive approach increases their ability to adjust management strategies to meet changes which are certain to occur within wildlife populations.

Item 5)  If you determine that Wyoming's State law and State wolf management plan do not constitute adequate regulatory mechanisms you can rest assured that Wyoming will challenge your decision as being arbitrary and capricious as you have already stated that Wyoming's law and wolf management plan were acceptable. You would be better off to explain to Judge Malloy what changes Wyoming has made to their plan which allowed the Service to deem their once unacceptable plan (2003) to an acceptable plan (2007). Furthermore, the Service should demand that the Department of Justice actively defend Wyoming's plan as your own actions have shown that wolves outside of the current trophy game zone have necessitated their removal. Human-wolf conflicts have continued to occur throughout the predator zone with at least 31 wolves being removed for their actions. In addition, 10 out of your 11 wolf experts have already gone on record stating that Wyoming's plan, in conjunction with Idaho and Montana's plan, was both scientifically and biologically sound. While some may not like to admit that the wolf is truly a predator, the facts remain that they are in fact predators. Wyoming's State law and State wolf management plan reflects the desires of its citizens. Enough public comments have been heard. Wyoming is obligated and has committed to maintaining 15 breeding pairs and a mid-winter population of a minimum of 150 wolves. The NRM DPS comprised of this non-essential, experimental population of gray wolves should be delisted and authority remanded to the States to implement them according to their approved science based and biologically sound plans and leave judicial activism out of wildlife management decisions.

Item 6)  Had Judge Malloy not interfered with the implementation of the delisting of wolves we would not need to assume anything. We could be reviewing what actually happened. This non-essential, experimental population of gray wolves has met recovery goals for 9 years. Adaptive wildlife management allows states to make corrections if any event threatens the respective states ability to maintain its obligation of maintaining 15 breeding pairs and a mid-winter population of a minimum of 150 wolves. Adaptive management does NOT alter the states commitment nor its obligation to maintain stated goals and objectives.

Item 7)  The Service must be able to establish DPS; otherwise, the recovery of listed species will become more expensive and less species will actually be able to meet recovery goals. The history of the ESA and its inability to effectively recover listed species as well as the current economic crises within our Nation, warrants that the Service have the ability to use DPS now more than ever. Perhaps the Service should provide the courts with an estimate of what the costs would be to recover a species such as the gray wolf to its entire former range as well as the feasibility of such actions ever being successfully completed without the Service being allowed to designate DPS.

In conclusion, the Service must uphold the long held process and tradition of allowing State agencies to develop and implement their own adaptive wildlife management plans as they are ultimately the entities which are providing wildlife management actions within their respective borders. Individual state agencies are better funded and more able to meet the readily changing needs of wildlife populations. This non-essential, experimental population of gray wolves occupying the NRM DPS has met and now exceeds recovery goals. All three affected States; Idaho, Montana, and Wyoming have committed to maintaining 15 breeding pairs and a mid-winter population of a minimum of 150 wolves. This provides the Service as well as the states a buffer of 15 breeding pairs and a minimum of 150 additional wolves. Given that additional wolves remain available for population augmentation should the need arise and that genetic diversity is virtually the same within the NRM DPS as their source populations in Canada, Judge Malloy's assumption that genetic exchange must be documented in order for delisting to occur is outlandish.

Thank you for your time and the opportunity to submit comments pertaining to Western Gray Wolf Delisting.

Respectfully,

Robert Wharff

Evanston, WY

USA

82930