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Endangered Species Permits
Supplement to the Environmental Assessment: Management of Wolf Conflicts and Depredating Wolves in Michigan
Below is the Introduction to the Supplement. Go here to view or download the complete SUPPLEMENT TO THE ENVIRONMENTAL ASSESSMENT: MANAGEMENT OF WOLF CONFLICTS AND DEPREDATING WOLVES IN MICHIGAN (26-page PDF)
In 2006, the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service, Wildlife Services (WS) and the United States Department of the Interior, Fish and Wildlife Service (USFWS) in consultation with the Michigan Department of Natural Resources (MDNR) prepared an Environmental Assessment (EA) on the potential environmental impacts of alternatives for managing gray wolf (Canis lupus) damage and conflicts in Michigan (USDA 2006). After consideration of information in the EA and public comments, on May 8, 2006, the federal agencies chose Alternative 2, Integrated Wildlife Damage Management, as the strategy to address wolf damage and conflicts in Michigan. The alternative permitted use of the full range of nonlethal and lethal methods to reduce wolf damage, and included USFWS issuance of a permit for the lethal take of depredating wolves. On August 9, 2006, a U.S. District Court in the District of Columbia enjoined the permit1 and all lethal take of wolves for depredation management was discontinued until March 12, 2007, when a February 8, 2007, USFWS decision to remove wolves from the federal list of threatened and endangered species went into effect (wolves were delisted). The March 12, 2007, delisting and a similar decision that went into effect on May 4, 2009, were challenged in court and, in each instance, status as an endangered species was restored (Table 1). While wolves have been federally-listed, the agencies have managed wolves in accordance with the 2006 EA and Decision with the exception that permits were not issued for the take of wolves for damage management. After the July 2, 2009, court settlement which returned wolves to endangered status, the MDNR requested a new permit to use aversive conditioning (e.g., shock collars; Hawley et al. 2009), nonlethal projectiles, and lethal methods to reduce wolf damage and conflicts. This supplement was prepared to update the analysis in the 2006 EA and to reevaluate USFWS options for the issuance of permits to the MDNR for wolf management in Michigan.
The ESA and an Endangered Species Act Section 6 Cooperative Conservation Agreement with the
USFWS grant the MDNR authority to conduct many types of wolf management and wolf damage
management activities without the need for a permit from the USFWS. In states with Cooperative
Conservation Agreements, any qualified and authorized employee or similarly qualified and authorized
agent of the state conservation agency may take an endangered species without a permit or 4(d) rule from
the USFWS provided the taking is not reasonably expected to result in: 1) the death or permanent
disabling of the specimen; 2) the removal of the specimen from the state where the taking occurred; 3) the
introduction of the specimen to an area outside the historical range of the species; or 4) holding the
species in captivity for a period of more than 45 days. (50 CFR 17.21 (c)(5)). Additionally, under the
ESA, anyone can take a wolf in response to an immediate and demonstrable threat to human life (i.e.,
when a wolf is attacking a person) without a permit from the USFWS. The ESA also grants the USFWS,
federal land management agencies, MDNR or their designated agents (e.g., WS) the authority to take
wolves in cases of non-immediate but demonstrable threats to human safety without a permit from the
USFWS. The USFWS, MDNR, federal land management agencies, or their designated agents, may take
a wolf to aid a sick or injured wolf.
The MDNR Permit request for the use of lethal WDM is similar to that analyzed in the 2006 Wolf EA and proposes the same level of take analyzed for Alternative 2 of the EA (10% of the previous winter wolf population). If the permit for lethal take of wolves for depredation management is issued, lethal removal of wolves would only be conducted under the following conditions:
In addition to evaluating the applicant’s request, the USFWS will consider whether to authorize lethal take of wolves for a study designed to compare the efficacy and impacts of nonlethal and lethal strategies for wolf depredation management. This proposed research is considered in a separate Alternative (Alternative 5 - Research Option). The Research Option would involve comparing sites using nonlethal methods for wolf damage management to sites using lethal methods for wolf damage management (See Section 3.4 below). Under the Research Option, only some of the sites involved in the study would be able to use lethal methods for WDM. The remaining study sites and all sites which are not included in the research project will only use nonlethal methods for wolf damage management. Consequently, the total lethal take of wolves for the Research Option would be less than the take if the MDNR damage management permit request is granted (Alternative 2).
1 Instead of contesting the Court’s decision, the USFWS chose to pursue the removal of wolves from the federal list of threatened and endangered species. However, the Safari Club International and Safari Club International Foundation were interveners on the case and continued to pursue the issue. In 2008, a three judge appellate panel vacated the District Court’s opinion.
Last updated: April 14, 2015