Gray Wolf (Canis lupus)
Archived Information - Wisconsin DNR Application for Permit to Take Gray Wolves
Response to Public Comments
Summary: The Wisconsin 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
18% per year since 1995, the confirmed depredation cases on Wisconsin
farms was variable ranging from 0 in the early years to at least 23 in
2005. 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 2001 public attitude survey of Wisconsin
bear hunters, farmers, and residents revealed 53% supported killing individual
wolves known to cause depredation. Support for killing wolves was highest
for bear hunters (77%), lowest for general residents (32%), and intermediate
for farmers (45%). 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.
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.
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. 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
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:
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.
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.
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.
the expertise, facilities, or other resources available to the applicant
appear adequate to successfully accomplish the objectives stated in
5. The wolf is a clan member. Taking wolves would marginalize tribal members
Response 5. Wisconsin tribes are working with WDNR 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 WDNR and the tribes. Any
taking would occur within ½ 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.
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."
7. Issuing a permit to take wolves violates ESA, NEPA, APA and sound science
before has the use of the scientific enhancement authority been used
for depredation control
such provision for taking endangered species for the purpose of depredation
control was provided by Congress in the ESA.
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
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.
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.
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.
9. FWS can not determine whether lethal wolf control actually reduces
losses for livestock producers-especially when conducted "preventively"
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).
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).
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).
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. WI DNR follows the "Wisconsin Guidelines for Conducting
Depredation Control on Wolves in Wisconsin While Federal listed as "Threatened"
or "Endangered" Status." 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. 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
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.
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. See Section 2.1.4. of the EA for additional information.
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 Wisconsin 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 WDNR 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.
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
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 WDNR 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).
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 WDNR 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. Wisconsin
tribes are working with WDNR 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 WDNR and the tribes.
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 Wisconsin DNR, making wolf carcasses available
to tribal members for cultural and educational purposes.
17. The states need a permit to resolve wolf-livestock problems (16 comments).
Response 17. The request from Wisconsin 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 Wisconsin's attempt to provide a prompt, professional,
effective program to resolve wolf conflicts in order to minimize negative
attitudes toward wolf recovery in Wisconsin and enhance wolf conservation
efforts. Section 3.0 of the EA discuss alternatives considered to resolve
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
Response 18. Concur. The Environmental Consequences of the alternatives
considered is evaluated in Chapter 4 of the EA.
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.
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."
21. Lethal control of problem wolves will not cause declines within the
region and will improve public acceptance and strengthen recovery program
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 Wisconsin. See Section 4.2.2.
of the EA for a full discussion.
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. In general, translocations are more likely to
be successful early in a recovery program when there are large amounts
of suitable habitat available to the species. From 1992 to 2002 wolves
were trapped and relocated in Wisconsin. No wolves returned to their original
depredation sites, but at least 3 (of 32) caused depredation at new locations.
Most of the captures and relocations in Wisconsin occurred in 2001 and
2002, but as of October 2005, only 4 were known to be alive. At least
one translocated wolf died from being killed by local wolves within the
release site. However, relocating wolves in recent years has become problematic.
There are currently eight Counties across northern Wisconsin that have
passed resolutions against the release of problem wolves into their counties.
As areas of suitable habitat are occupied and the flexibility for translocating
wolves is restricted, these problems are likely to exacerbated.
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.
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
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
Wisconsin wolf population.
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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