Gray Wolf (Canis lupus)
Archived Information - Michigan DNR Application for Permit to Take Gray Wolves
Response to Public Comments
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Summary:
The Michigan Department of Natural Resources (DNR) submitted an application
for a permit to take gray wolves in order to conduct various recovery
activities for the species. A notice of the application was published
in the Federal Register on September 14, 2005. That notice opened a 30-day
comment period on the application. The Fish and Wildlife Service requested
written comments on the permit application by October 14, 2005. Below
is a summary of comments received followed by a response from the U.S.
Fish and Wildlife Service.
Comment
1. Killing wolves is not justified or needed (3 comments).
Response 1. Studies have found public support for the presence
of large carnivores largely depends upon their confidence that problems
caused by individual animals will be resolved effectively. Lethal control
of depredating individuals is one aspect of wolf population management
as populations expand and increase into agricultural areas, and is conducted
to maintain tolerance and acceptance of wolves in rural areas. The concept
of lethal controls on wolves preying on livestock is strongly supported
by wolf managers and biologists/scientists throughout wolf range, even
in recovering populations. While the wolf population increased approximately
19% per year since 1996, the annual rate of confirmed depredation cases
was variable ranging from 0% to 4%. An appropriate management response
to depredation is to address the negative interactions and target problem
wolves in a local area. Removing wolves responsible for depredations can
reduce the negative interactions that create intolerance for wolves. A
2002 public attitude survey of Michigan residents revealed 75% in the
Lower Peninsula and 85% in the Upper Peninsula supported killing individual
wolves known to cause depredation. If there is no legal relief from the
loss of livestock, intolerant stakeholders will likely resolve their own
depredation problems. See Section 2.2.4 in the EA for additional
information.
Comment
2. No scientific basis for killing depredating wolves (single comment).
Response 2. The Wildlife Society, an international organization
of professional wildlife biologists, especially focused on North America,
states that “Control of wolves preying on livestock and pets is imperative
and should be prompt and efficient if illegal killing is to be prevented
and human tolerance of the presence of wolves is to be maintained (Peek
et al.1991). The International Union of Nature and Natural Resources or
World Conservation Union has established a “Manifesto on Wolf Conservation”.
The “Manifesto” was published in International Wolf Magazine
in 1994 (Anonymous 1994). The 7th Principle for wolf conservation stated
“It is recognized that occasionally there
may be a scientific established need to reduce non-endangered wolf populations;
further it may become scientifically established that in certain endangered
wolf populations specific individuals must be removed by appropriate conservation
authority for the benefit of the wolf population.” In an extensive
literature review of strategies for reducing carnivore/ livestock conflict
by Norwegian biologists, it was concluded that lethal control should be
considered on endangered carnivores such as wolves to prevent expansion
into areas of high conflict (Linnell et al. 1996). Lethal control activities
by government agents have been authorized on wolves in Minnesota since
1978, when they were downlisted to a threatened population (Fritts et
al 1992). This selective removal of problem wolves resulted in the capture of 2430 wolves, and killing of
2261 wolves between 1979 and 2003 (Paul 2003). Annual number of captured
and killed wolves ranged from 6 in 1979 to 216 in 1997, but declined to
125 in 2003 (Paul 2003). Despite these lethal controls, the Minnesota
wolf population increased from an estimated 1235 in
1979 to 3020 in 2004 (Erb and Benson 2004). Although wolf numbers have
continued to rise, the distribution of the wolf population has stabilized
to heavily forested portions of the state, and the previous spread into
agricultural areas has halted; this is possibly due in part to the control
activities, reducing presence of wolves in areas of conflict. See Section
2.1.5 in the EA for additional information.
Comment
3. Non-lethal control measures are available (2 comments)
Response 3. Non-lethal means of controlling depredating wolves
are generally more readily accepted by the public. The disadvantages of
non-lethal controls can be that many are costly, time-consuming, and their
effectiveness declines over time. Although extensive research has been
conducted to develop effective non-lethal control techniques, none have
been developed that can be broadly used in a wide variety of wolf depredation situations (Schultz et al. 2005, Shivik 2004, Shivik et al. 2003). Most
non-lethal procedures are most useful if they can be applied before wolves
have started killing domestic animals, and have habituated to livestock.
But non-lethal controls have not been adequately developed to eliminate
the need for lethal controls (Fritts et al. 2003).
4.Comment Section 10(a)(1)(A) is not an appropriate tool to take endangered
species for depredation control. Should only be used to benefit the species (7
comments)
Response
4. The following issuance criteria found in 50 CFR §17.22 are
used by the Fish and Wildlife Service in determining whether to issue
permits for scientific purposes, enhancement of propagation or survival:
· Whether the purpose for which the permit is required is adequate
to justify removing from the wild or otherwise changing the status of
the wildlife sought to be covered by the permit.
· The probable direct and indirect effect which issuing the permit
would have on
the wild populations of the wildlife sought to be covered by the permit.
· Whether the permit, if issued, would in any way, directly or
indirectly, conflict
with any known program intended to enhance the survival probabilities
of the
population from which the wildlife sought to be covered by the permit
was or
would be removed.
· Whether the purpose for which the permit is required would
be likely to reduce
the threat of extinction facing the species of wildlife sought to be
covered by the
permit.
· The opinions or views of scientists or other permits or organizations
having
expertise concerning the wildlife or other matters germane to the application.
· Whether the expertise, facilities, or other resources available
to the applicant
appear adequate to successfully accomplish the objectives stated in
the
application.
Comment
5. The wolf is a clan member. Taking wolves would marginalize tribal
members (2 comments)
Response 5. Michigan tribes are working with MDNR to address concerns
regarding wolf management on ceded territories and wolf management in
the vicinity of tribal lands. Wildlife Services’ WDM actions will
be conducted in accordance with agreements and MOUs between MDNR and the
tribes. Any taking would occur within one mile of the depredation site.
If trapping or shooting would be done on state, federal, or commercial forest lands, the owner or managing authority would be contacted for permission. Control
on tribal lands would only be done if requested by the Tribe.
Comment
6. There is no evidence taking wolves legally will reduce illegal
take of wolves (2 comments).
Response 6. Illegal killing does continue to occur in all protected
wolf populations. Shooting during hunting seasons occurs every year. Placement
of illegal traps, snares, and poisons occasionally occurs as well. In
Wisconsin, the highest illegal kill detected in recent years occurred
in 2002, when at least 15 illegally shot wolves were found in the state. In most years the overall death rate is biased by dead wolves that
were easily found such as vehicle kills, and under represents illegally
killed wolves. Death rates based only on radio-collared wolves usually
provides a less biased assessment of wolf mortality, but collared wolves
usually have a low sample size of death rates. Both death
rates (radio-collared and total) are of value to assess overall wolf mortality
and illegal kill. There is some indication that illegal kill was on the
rise before lethal control activity was authorized in 2003. The rate of
collared illegal kill in 2005 suggests that illegal kill may again be
on the rise, possibly reflecting frustrations with federal delisting and
the
federal court actions. In March 2005, poisoned dog food, probably set
for wolves, was found in several locations in Ashland and Price Counties,
suggesting attempts to reduce wolf numbers shortly after the 4(d) rule
was eliminated and lethal control ceased. Fritts (1990) states that “When
depredation on livestock occur, control actions are
imperative…..Leaving problem wolves in the population may exacerbate
the level of wolf-livestock conflict in the long run…..Wolf-human
conflicts will precipitate illegal killing by the public, regardless of
the penalty.” Fritts (1990) further states, “Control of problem
wolves is expected to reduce the hostility toward wolves that would result
in
illegal killing.”
Comment 7. Issuing a permit to take wolves violates ESA, NEPA,
APA and sound science (single comment).
·
Never before has the use of the scientific enhancement authority been
used for depredation control
· No such provision for taking endangered species for the purpose
of depredation control was provided by Congress in the ESA./
· Use of Section 10(a)(1)(A) for depredation control purposes
is particularly troubling as it violates the terms of an injunction
levied by a federal district court and blatantly flouts the authority
and ruling of that court
The use
of the requested permits for depredation control purposes may have a
significant environmental impact, necessitating the completion of an EIS or, at
a minimum, an EA.
Response
7. See Section 1.8.2. of the EA for compliance with Federal and State
statutes and Section 2.2.4., Chapter 4, and Response 2 for a discussion
of sound science.
Comment 8. The livestock losses in MI and WI are minor (single
comment).
Response 8. Wisconsin provides the most complete picture of depredation
in a rapidly expanding wolf population in the Midwest. In recent years
there has been an increase in wolf depredation as wolves have saturated
most large forested areas in northwest and north-central Wisconsin, and
have begun to occupy more agricultural areas. The numbers of farms with wolf depredation was 8 in 2002, 14 in 2003, 22 in
2004 and 23 so far in 2005 (as of 10/14/05). In 2003 17 wolves were trapped
and euthanized on farms in the state or 5.1% of the previous winter population.
In 2004, 27 wolves were captured and 24 were euthanized or 6.4% of the
previous winter population. In 2005, 29 wolves were trapped and killed
at depredation sites or 6.8% of the previous winter wolf population. In 2005, 6 probable wolf-dog hybrids were also caught at depredation
sites, and these are currently being genetically tested. When viewed against
the total livestock production of Wisconsin, wolf depredation is admittedly
very small. However, when viewed from the perspective of an individual
owner, the loss of only a few head of livestock is seen as serious. Livestock
owners that are not provided legal relief from depredation will have an
increasing tendency to seek some form of relief and protection for their
animals, whether it is political action (changes to the ESA) or illegal
action.
Comment 9. FWS can not determine whether lethal wolf control actually
reduces losses for livestock producers—especially when conducted
“preventively” (3 comments).
Response 9. None of the alternatives propose “preventative
lethal control.” For lethal control as a response to depredation,
Haight et al. (2002) conducted a computer simulation of 3 types of wolf
removal on a simulated subset of a western Great Lakes wolf population.
The three strategies include reactive management (government control on
verified depredations), preventive management (similar to pro-active controls
by government trappers), and population-size management (similar to a
public hunting/trapping seasons). Under the various scenarios, reactive
managements reduced depredation by 40% or greater, had minor impact on
wolf population growth, and posed
almost no risk of wolves becoming endangered or threatened (< 100 wolves
in an area able to support 64 wolf packs). The other strategies generally
resulted in greater reductions of depredations, but also considerably
lower wolf populations, and under some scenarios, posed greater risks
of wolves becoming endangered (Haight et al. 2002). Across North America,
livestock losses to wolves have been low in recent years, during a period
when lethal controls were available across much of wolf range (Fritts
et al. 2003). Depredations would probably have been much higher if not
for the removal of problem wolves (Fritts et al. 2003). Once conditioned
to feeding on domestic animals, any of these pack members are likely to
feed on other livestock when the opportunity presents itself. Lethal removal
of wolves generally reduces depredation for the remainder of a grazing
season, but in areas of high quality habitat, new packs may recolonized
by the next year (Fritts et al. 1992).
While good
husbandry practices are promoted in the various alternatives (Appendix
B of EA) as preventive management, no lethal preventive management is
proposed for any of the alternatives. Lethal control will occur only when
depredation has been verified (see response 10 below).
Comment 9. FWS can not determine whether lethal wolf control actually
reduces losses for livestock producers-especially when conducted "preventively"
(3 comments).
Response 9. None of the alternatives propose "preventative lethal
control." For lethal control as a response to depredation, Haight
et al. (2002) conducted a computer simulation of 3 types of wolf removal
on a simulated subset of a western Great Lakes wolf population. The three
strategies include reactive management (government control on verified
depredations), preventive management (similar to pro-active controls by
government trappers), and population-size management (similar to a public
hunting/trapping seasons). Under the various scenarios, reactive managements
reduced depredation by 40% or greater, had minor impact on wolf population
growth, and posed almost no risk of wolves becoming endangered or threatened
(< 100 wolves in an area able to support 64 wolf packs). The other
strategies generally resulted in greater reductions of depredations, but
also considerably lower wolf populations, and under some scenarios, posed
greater risks of wolves becoming endangered (Haight et al. 2002).
Across North
America, livestock losses to wolves have been low in recent years, during
a period when lethal controls were available across much of wolf range
(Fritts et al. 2003). Depredations would probably have been much higher
if not for the removal of problem wolves (Fritts et al. 2003). Once conditioned
to feeding on domestic animals, any of these pack members are likely to
feed on other livestock when the opportunity presents itself. Lethal removal
of wolves generally reduces depredation for the remainder of a grazing
season, but in areas of high quality habitat, new packs may recolonized
by the next year (Fritts et al. 1992).
While good
husbandry practices are promoted in the various alternatives (Appendix
B of EA) as preventive management, no lethal preventive management is
proposed for any of the alternatives. Lethal control will occur only when
depredation has been verified (see response 10 below).
Comment
10. FWS has no way to assess whether those individuals who request
lethal control have incorporated non-lethal methods or have incorporated
or improved their livestock husbandry practices (single comment).
Response 10. MI DNR follows the "Guidelines for management
and lethal control of wolves following confirmed depredation events."
Before lethal control methods can be used, DNR or USDA-WS personnel trained
on depredation investigation techniques must verify depredation during
a site visit. Depredation events are complicated to investigate, available
evidence is often incomplete, and there will be varying levels of difficulty
in confirming wolf kills. Whenever possible, individuals with the most
experience investigating depredation incidents should conduct the site
visit. However, because it is critical to initiate an investigation as
soon as possible, there will be times when experienced investigators are
not available. In those instances, other personnel that have received
training should travel to the site, meet with the livestock producer,
and begin the investigation. However, if the evidence is not clearcut,
a more experienced investigator should investigate. In all cases, the
final determination will be at the discretion of the Management Unit Supervisor.
Available non-lethal methods to resolve wolf-livestock conflicts include
improving animal husbandry practices, protection of livestock (e.g., fencing,
livestock guarding animals), harassment (e.g., strobe light/siren devices),
and translocation (trapping and relocation of depredating wolves). Non-lethal
methods will be offered to livestock producers when wolves are known to
be in an area where livestock are being housed or pastured, and there
is a legitimate complaint that wolves are harassing, injuring or killing
livestock. The legitimacy of these complaints will be evaluated in the
field by DNR or USDA-WS personnel. A credible observation of wolves in
an area frequented by livestock does not constitute enough of a threat
to initiate the use of harassment techniques or translocation. All of
these measures are detailed in the information pamphlet "How to Live
With Wolves in Michigan." This pamphlet is being developed and will
be made available through the Farm Bureau, Michigan State University Extension,
and the DNR.
Comment
11. Oppose trapping. Research indicates that the use of leghold traps,
leg snares, and neck snares to restrain or kill wildlife has the potential
to cause serious injury and a prolonged, painful death (single comment).
Response 11. Wildlife Services personnel are experienced and professional
in their use of WDM methods. Wolves would be trapped, snared, or shot
by experienced WS personnel as humanely as possible using the best methods
available. Tranquilizer trap devices (TTDs) can be used on wolf traps
to reduce the incidence of self-inflicted injuries by captured animals.
Wildlife Services is not exempt from Michigan dry land trapping regulations
which require dry land trap sets to be checked at least once each day.
Daily trap checks minimize the amount of time target and non-target animals
remain in traps, and improve the likelihood that a non-target animal may
be released unharmed.
Comment
12. Any depredation control program should consider lethal control
only as a last resort, and only after non-lethal efforts have been exhausted.
When and if lethal control is deemed necessary, it should target only
the depredating wolf, not all wolves in the general area, and should be
conducted in the most humane manner possible (2 comments).
Response 12. An Integrated Wildlife Damage Management (IWDM) program
is proposed to be used in Michigan to protect resources from gray wolf
damage and promote wolf recovery. The strategies considered encompass
use of the full range of legal, practical and effective methods of preventing
or reducing damage and conserving the wolf population while minimizing
harmful effects of damage management measures on humans, wolves, other
wildlife species and the environment. As proposed, WS and the MDNR would
provide technical assistance and operational damage management, including
non-lethal and lethal management methods selected after applying the WS
Decision Model (Slate et al. 1992). This is described in full detail in
Section 3.1.2. of the EA. We concur with your statement that the target
should only be depredating wolves. If segments of the public take action
out of frustration from lack of legal alternatives, it is far less likely
that the appropriate animals would be targeted and much more likely that
the population as a whole would suffer.
Comment
13. The FWS should consider issuing the states permits that allow
only scientific and non-lethal management activities (single comment).
Response 13. The FWS will consider the full range of the permit
request as well as a number of alternatives including only scientific
and non-lethal management activities.
Comment
14. Depredation investigation, control activity, or scientific take
should not occur within tribal reservations without prior consultation
with the affected tribe (2 comments).
Response 14. Wildlife Services would only be involved in wolf damage
management as an agent of MDNR or as requested by a tribe. All WDM activities
would be consistent with other uses of the area and would comply with
appropriate Federal, State and local laws and in cooperation with other
governmental agencies and tribal governments, as appropriate. Depredation
control would not occur on tribal land without a request and written concurrence
from the tribe (see Section 1.4.2 of EA).
Comment
15. Depredation cases within a 6 mile buffer area around reservation
lands should be coordinated with the respective tribal entity (single
comment).
Response 15. Wildlife Services would only be involved in wolf damage
management as an agent of MDNR or as requested by a tribe. All WDM activities
would be consistent with other uses of the area and would comply with
appropriate Federal, State and local laws and in cooperation with other
governmental agencies and tribal governments, as appropriate. Michigan
tribes are working with MDNR to address concerns regarding wolf management
on ceded territories and wolf management in the vicinity of tribal lands.
Wildlife Services' WDM actions would be conducted in accordance with agreements
and MOUs between MDNR and the tribes.
Comment
16. Carcasses of 50% of wolves taken for depredation should be made
available for cultural and educational uses by member tribes (single comment).
Response 16. The Fish and Wildlife Service will consider, in coordination
with Wildlife Services and Michigan DNR, making wolf carcasses available
to tribal members for cultural and educational purposes.
Comment
17. The states need a permit to resolve wolf-livestock problems (16
comments).
Response 17. The request from Michigan is based on wolf predation
on and threats to livestock, game farm animals and pets, and risks to
human health and safety from potentially hazardous or threatening wolves.
The permit application is Michigan's attempt to provide a prompt, professional,
effective program to resolve wolf conflicts in order to minimize negative
attitudes toward wolf recovery in Michigan and enhance wolf conservation
efforts. Section 3.0 of the EA discuss alternatives considered to resolve
wolf-livestock issues.
Comment
18. Permits to take wolves will enhance the long-term conservation
of the wolf by responding to public concerns, garnering support for wolf
management, and improve research and monitoring capabilities of the agencies
(single comment).
Response 18. Concur. The Environmental Consequences of the alternatives
considered is evaluated in Chapter 4 of the EA.
Comment
19. Depredation control is consistent with scientific wildlife management
and would enhance the conservation of the species range-wide (2 comments)
Response 19. Concur. This is discussed in Chapter 4 of the EA.
Comment
20. Permit authority is consistent with the intent of ESA (single
comment).
Response 20. Concur. Gray wolves are currently federally listed
as an endangered species under Section 4 of the Endangered Species Act
(ESA). While federally listed, primary management authority for wolves
rests with the USFWS. Under the provisions of the ESA, the USFWS may grant
permits for the take of a federally listed species for, "scientific
purposes or to enhance the propagation or survival of the affected species,
including, but not limited to, acts necessary for the establishment and
maintenance of experimental populations pursuant subsection (j); or (B)
any taking otherwise prohibited by section 9(a)(1)(B) if such taking is
incidental to, and not the purpose of, the carrying out of an otherwise
lawful activity."
Comment
21. Lethal control of problem wolves will not cause declines within
the region and will improve public acceptance and strengthen recovery
program (4 comments)
Response 21. Concur. We believe the proposed action is unlikely
to cause a decline in annual recruitment and will not appreciably reduce
the survival or recovery of the wolf in Michigan. See Section 4.2.2. of
the EA for a full discussion.
Comment
22. Relocation of problem wolves is preferred over lethal take when
possible. However, lethal control should be used where depredating wolves
can not relocated (single comment).
Response 22. Concur. From 1996 to 2003 wolves were trapped and
relocated in Michigan. However, relocating wolves in recent years has
become problematic. Given the current widespread distribution of wolves
in the Upper Peninsula, there is a high probability that relocated wolves
would be killed by packs occupying the area of release or the area the
relocated individual passes through while moving away from the release
site. Additionally, public observations of relocations of depredating
wolves by DNR personnel contributes to the (incorrect) belief among certain
residents the agency has been transplanting wolves from outside Michigan
to the Upper Peninsula and will continue to do so.
Comment
23. Lethal control of wolves would secure the continued support for
wolf populations from farmers and bear hunters. Support of these groups
is vital (single comment).
Response 23. Concur. Public support is critical for the viability
of the wolf population. Removal of depredating wolves from the population
promotes that support.
Comment
24. Wolves have an intrinsic value resting in the existence of the
species rather than in individuals. Therefore, it is acceptable to kill
a few wolves to guarantee survival of the species. The policy of lethal
control for depredating wolves offers the best long term chance for survival
(2 comments).
Response 24. Concur. Negative public perception of the wolf was
the primary reason this species was historically extirpated from the much
of the lower 48 states. Negative views of the wolf, reflected in legislation
supporting wolf bounties and wolf trapping systems, nearly eliminated
this species from the conterminous United States. More recently the general
public adopted more favorable views of the wolf. The increase in public
support was critical in recovery of the wolf in Minnesota, Wisconsin and
Michigan. Negative views of wolves still persist today in certain segments
and despite the legal protection to this species afforded by the ESA,
these negative perceptions have the potential to adversely impact the
Michigan wolf population.
Comment
25. WDNR paid out $110,000 during 2004 in wolf depredation payments.
Approximately $35,000 was obtained from tax check-off and license plate
sales; the remaining $75,000 came from endangered resource and non-game
funding sources. Without the ability to euthanize depredating wolves,
the amount taken from other conservation programs will grow rapidly (single
comment).
Response 25. Concur.
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