Although I earlier posted a lot of material about the USFWS proposed changes to the 10j rule on the “non-essential, experimental” population of wolves in Idaho, Wyoming, and much of Montana, a month ago, I’ve been asked to post again now that the due date approachesAugust 6.

Here is the proposed new 10j rule as it was published in the Federal Register on July 6.

What do these changes mean? Fact sheet from Defenders.

What is the worst part? It is the new allowance for killing of wolves by the government for “herd management” purposes. The proposed new rule defines “herd management” in such a way that a state could kill wolves that affect ungulate herds in any manner they choose to find objectionable. It is no longer just a reduction in the herd’s size that may merit state ordered killing, it might just be that wolves have made elk more wary and so harder for the least capable hunters to find. In other words, some of the beneficial reasons why wolves were restored under 10j rule, may now be the basis for their termination — wolves just being wolves and making the elk, deer, and moose more wild, could result in an order from them to be gunned down.

Here’s what it says in the Federal Register about wolves having an unacceptable impact on “herd management goals.”

Unacceptable impact—State or tribally determined impact to a wild ungulate population or herd, with wolves as one of the major causes of the population or herd not meeting established State or Tribal population or herd management goals.

How do you comment?

Here is what it says in the Federal Register.

1. If you submit comments by e-mail, please submit them in ASCII file format and avoid the use of special characters and encryption. Please note that the e-mail
address will be closed at the termination of the public comment period [Aug. 6].

2. Email directly to the Service at WolfRuleChange@fws.gov. Include ‘‘RIN number 1018–Av39’’ in the subject line of the message.

3. You may submit your comments through the Federal e-Rulemaking portal—http://www.regulations.gov.

4. Include your real name, your address, phone number, email address.

Will your comment make a difference?

I think the USFWS is determined to do this. However, if you raise new issues, they are bound by law to consider them, and if they don’t that can be the basis for litigation (which I assume will follow this outrage).

The most important thing to do is to send a copy of your comments or just your general objections to your US Representative and both of your US Senators. They may not know this is an issue. You don’t have a due date for contacting your members of Congress. Contact them even if you live in Wyoming or Idaho.

It does no good to contact members of Congress other than your own. So if you live in Kansas, let’s say, contact your Kansas members of Congress.

Here is a link to the US House and the US Senate. You can use this to contact your members of Congress (most require using their form; this was done to prevent spam).

Defenders of Wildlife and Natural Resources Defense Council have ready made letters to send. These are well written and you might use them as a basis, but I think it is the lazy person’s way of contacting them, and identical form letters will be heavily discounted by the USFWS.

 
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About The Author

Ralph Maughan

Dr. Ralph Maughan is professor emeritus of political science at Idaho State University with specialties in natural resource politics, public opinion, interest groups, political parties, voting and elections. Aside from academic publications, he is author or co-author of three hiking/backpacking guides, and he is President of the Western Watersheds Project.

12 Responses to There is still time to comment on the proposed new (and just plain awful) wolf rules.

  1. avatar Matt says:

    Ralph, thanks for keeping us all updated on this legislation. I just left my comments on the regulations.gov site, and I’ll be contacting my congressional representatives shortly.

  2. avatar Mike says:

    What is the best way to contact our members of congress?
    phone, email, letter

  3. Phone or email. Snail mail has to go through all the terrorist detection stuff and it takes a long time to get there.

  4. avatar Robert Wiley says:

    I left my comments supporting the new 10J rules. Awful? hardly!!! I like them.

  5. avatar JEFF E says:

    ooooooo Robert, you’er a real man

  6. avatar elkhunter says:

    Robert you will soon realize Jeff E will make sarcastic remarks if you are not willing to sacrifice all for wolves.

  7. avatar Joe S. says:

    These changes to to 10j rule mark the first sensible proposal since the wolf intro!!!!!

    Comments sent

  8. avatar skyrim says:

    Ya, it’s make it tough on slob hunters. Back in the old days (prior to 95) you used to be able to plink ’em right from the interstate. Damn wolves drove ’em deeper into the woods where a guy has to actually wander in there. Scary place, the woods…. bugs and stuff……

  9. avatar Joe S. says:

    Sky…i too share your disgust for slob hunters…..cant say i’ve seen any shooting from the interstate….but obviously we run in different circles….
    I do however look forward to buying an idaho wolf tag, hiking deep into the “scary” woods and slipping an arrow just behind the shoulder….2009>>?

  10. avatar JEFF E says:

    question joe,
    once you do all that will you be eating it, using the pelt, or otherwise respecting the life you just ended? If not you are just another slob hunter.

  11. avatar sal says:

    News from a grapevine this morning…

    The USFWS will be conducting an EA (Environmental Assessment, I believe) which will require an additional comment series.

    Not sure of any other particulars but that’s the process. The additional comment period request on the 10(j) rule change was not addressed by the Service.

    The date of publication of the announcement in the Fedreal Register will start the clock.

  12. From the Webmaster-

    I’ve been gone for about six days. When I got home a couple hours ago, there was a queue of personal insults that WordPress had flagged waiting for my approval to post.

    I can’t see any reason to approve them, so this notice is the last comment on this thread, which I am now closing.

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Quote

‎"At some point we must draw a line across the ground of our home and our being, drive a spear into the land and say to the bulldozers, earthmovers, government and corporations, “thus far and no further.” If we do not, we shall later feel, instead of pride, the regret of Thoreau, that good but overly-bookish man, who wrote, near the end of his life, “If I repent of anything it is likely to be my good behaviour."

~ Edward Abbey

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