Montana Fish, Wildlife & Parks 1420 East Sixth Avenue P.O. Box 200701 Helena, MT 59620-0701 Attn: Commissioners Re: Comments on Proposed Wolf Hunting Regulations, 2014-15 June 23, 2014 Dear Commissioners: It is our understanding that the Commission is considering its 2014-15 wolf-hunting season. We believe that wildlife management should be based on best available, peer-reviewed science and the democratic principles that guide decision-making. Therefore, based on the evidence provided in this position statement, we hope you consider our serious concerns herein prior to your final decision re: wolf season recommendations for 2014-15. In general, we would like to openly express our opposition to hunting of all predators, especially wolves, with the possible exception of extremely rare (and confirmed) threats to people, pets and property. A great body of scientific work confirms when it comes to wolves, it’s not about quotas. A wolf is a wolf when it’s part of an intact, unexploited group capable of complex cooperative behaviors and unique traditions. If a pack is left unexploited, it will develop its own traditions for hunting, pup-rearing, and social behaviors that are finely tuned to its precise environment. Wolves should not be managed by simplistic models most commonly used by today’s wildlife agencies. The notion that we can “harvest” a fixed percentage of an existing wolf population that corresponds to natural mortality rates and still maintain viable populations of wolves does not reflect the most current, peer reviewed research. If we leave wolves alone, they will manage their own numbers in concert with their environment. And, if we leave wolves alone, we will be the ones to benefit – for the presence of wolves contributes to the balance of the wild lands. That said, it is our understanding that FWP is seeking comment on three wolf-related proposals: (1) closing the hunting and trapping season in Wolf Management Units 313 and 316 within 12 hours of the harvests quotas there being reached. These WMUs border Yellowstone National Park. The proposal also includes reducing the harvest quota in WMU 313 from four to three wolves; (2) offering the opportunity to trap wolves via a drawing on three western Montana wildlife management areas, including the BlackfootClearwater, Fish Creek and Mount Haggin WMAs; (3) a statewide annual quota of 100 wolves taken under a new state law that provides for landowners to take wolves without a license that are a potential threat to human safety, livestock or pets. We share the following comments with the acknowledgment that FWP does not share our overall understanding and interpretation of the science regarding wolf ecology and with the hope that we can encourage the Commission to reconsider all or portions of said proposals moving forward.

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Comments: 1.

Regarding the proposal to allow up to 100 wolves to be killed on private lands: We believe this quota is woefully excessive, inappropriate and not based on the best available science. It will allow additional killing of wolves on private lands through loopholes that are difficult to enforce or even define. Last year, it was our understanding that only 8 wolves were killed by lethal take permits that allowed private citizens to kill wolves seen in the act of attacking, killing, or other "threatening" of livestock. This arbitrary quota of 100 must be reduced to more appropriately address the realistic needs of landowners based on the historical record – not hate. This quota also sends the wrong message to private landowners because it enables wolves to be killed outside of already aggressive hunting and trapping seasons. In essence, it allows wolf hunting year round. Wolves are not vermin that should be shot based on a perceived threat with little or no documented evidence and without consideration for their ecological loss. Wolves are wildlife and should be treated with respect like all other wildlife. We also don’t support people taking measures into their own hands; landowners should be required to obtain a permit and to contact the department before carrying out any lethal action. Finally, it there must be a quota at all, the wolves killed because of SB 200 should count toward the general hunting quota and if exceeded, count against the next year's hunting quota. Sharing the landscape with large carnivores should be the rule and not the exception, however.

2.

We do not support the reduced quota for wolf management unit (WMU) 313 to three wolves. Southwest Montana's landscape is critical for the conservation of wolves inside of Yellowstone National Park. It provides the world's greatest opportunities for viewing and researching wild wolves. Wolf watching in this area brings tens of thousands of people into the region annually and substantially benefits the economies of gateway communities that thrive on a booming ecotourism industry. Scientific studies of predator/prey relationships and wolf behavior are important to the Yellowstone Wolf Project. Minimizing human disruption from hunting and trapping of wolves benefits the research that FWP often cites for developing its own wolf policies, as well. Therefore, we believe no hunting/trapping should be take place in these units.

3.

We support reducing the closure period for WMU's 313 and 316 from 24 hours to 12 hours so that FWP can more accurately limit hunting when quotas are met.

4.

We oppose all forms of wolf trapping. Specifically in terms of FWP’s proposal, all trapping should be prohibited in wolf management units 313 and 316 to minimize the collateral killing of threatened species vulnerable to trapping, such lynx and wolverine. There continues to be support for wolves in southwest Montana. Again, wolf watching greatly contributes to the region's economy. These values should be included in FWP objectives for wolf management.

5.

We request that wolf hunting quotas be re-established in the state. Many WMU's exceeded a 50% mortality of known wolves within a given WMU in 2013. It's time for FWP to reinstate quotas by WMU to ensure a sustainable population of wolves is distributed across suitable habitat in Montana. In 2013, sheep and cattle depredation declined from 2012 and the vast majority of elk management 2

units are above or within their stated objective. It's time for FWP “manage” wolves based on evidence and impose these restrictions on wolf hunting throughout the state. Science has taught us that drastic and sudden reductions in wildlife populations can have broad implications on the health of a species. In the case of wolves, which have complex social networks, it can lead to the disruption of existing packs and a loss of genetic diversity. Because of this, wolf management plans and proposed legislation must adequately and appropriately consider all aspects of the wolves' ecology in their proposals and practices. 6.

We ask that FWP consider all lethal removals by USDA’s Wildlife Services as well as other humancaused (i.e. poaching, etc.) and non-human caused mortality when considering wolf population estimates.

We appreciate this opportunity to submit these comments on Montana's tentative wolf hunting and trapping seasons. Please consider revising the 2014-2015 wolf hunting and trapping proposal to better protect Montana’s wolves in a manner that reflects a growing majority of stakeholders. Respectfully submitted, Action and Awareness Committee, Wolf Conservation Center Maggie Howell, Executive Director Helene Grimaud, Board Member Diane Bentivegna, Educator and Advocate

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