On the the new wolf delisting scheme

Wyoming is the biggest thorn in the delisters side-

As folks pretty much all know, the Bush Administration, mostly likely at the initiative of Secretary Kempthone and cronies, is trying for one last quick stab at delisting the wolf before a new President replaces them.

If folks work hard, they will probably be defeated again; but their era of extremism and backward thinking may not end quite quick enough, so this delisting thing has to get your attention.

Here is the notice from the Federal Register indicating how to send in your comments beginning now. They are all due by Nov. 28.

Notice of reopening of comments on delisting. Federal Register. Don’t be deterred by having to go to regulations.gov to submit your comments.

They claim that if wolf population genetics deteriorates (a major objection from Federal Judge Molloy who shot down their delsiting), now they will shuttle wolves around to Wyoming to improve the genetics.

The have an unsigned MOU (Memorandum of Understanding) on this. Draft MOU. (note that Jeff commented and posted this earlier in a comment).

Because Wyoming needs to make changes, their Department of Game and Fish is trying to engage in some emergency state rulemaking. They just issued this news release.

Game and Fish Releases Draft Revised Wolf Plan for Public Comment. Wyoming Dept. of Game and Fish.

Their emergency rules. Wyoming Dept. of Game and Fish. Hearings are scheduled and soon. This is rush job.

My impression of the emergency rules is that they are not much of a change because the Department can do little without a change in Wyoming’s wolf hostile statute on wolf management. Their state legislature doesn’t meet until January, which would be best time to make Wyoming’s wolf plan acceptable, but the presidential election dictates action now.

Little doubt what Kempthorne wants is to decouple Idaho and Montana, where they manage wolves “so well” from Wyoming — just delist 2 states and let Wyoming wolves limp along indefinitely, maybe with what amounts to a “put and take” translocation of fresh wolves whenever the state kills too many. Kempthorne proposed this to the Secretary of Interior when he was governor of Idaho. Now as the Secretary, this is his last shot.

Do be fooled, however. Idaho has a bad wolf plan and Montana, which had earned some applause,  has been killing wolves this year with a vengeance despite incredibly minor depredations.

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Brief AP news story. Wyoming proposes changes in its wolf plan. By Bob Moen.



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  1. caleb Avatar


    Two things about this.
    1. The MOU which I looked at a few days ago states that each state will list the wolf as Trophy, Big game, or in Need of Management, throughout the entire state. Wyomings emergency rules are the same with the predatory and trophy game areas. They changed hardly a thing.
    2. What is up with the states especially WY trying to consider the wolves in the National Parks as the 10 breeding pairs. If that is the case then WY would not have to keep hardly any wolves outside of the parks alive. The states should not be allowed to count the wolves inside the parks as a state breeding pair that is different.

  2. jerry b Avatar
    jerry b

    For those that haven’t figured out the “regulations.gov” site and how to get to the “comment” page, if you go to “regulations.gov” home page and type in “fws-r6-es-2008-0008-0002” in the search documents box, it will take you to the “send a comment” page. Maybe it’s just me that found it so difficult but this saves time.

  3. Ralph Maughan Avatar


    Wyoming has never agreed to keeping more than 7 or 8 breeding pairs outside the Park. They have always thought and argued that the Park will have 10 or more breeding pairs to make sure that Wyoming, as a whole has 15 breeding pairs (only ten are required to prevent relisting of the wolf).

    They never anticipated, and are probably just waking up to the fact that this year the Park has no more than 5 breeding pairs (and I think by the end of the season, it could be a low as just two).

    I only figured this out this week.

  4. Ralph Maughan Avatar

    A “breeding pair” of wolves consists of a male and a female who mated, had at least 2 pups, and both the pups and both parents were alive 7 months later at the end of the calendar year.

    So if a pack loses its alpha female during year, even if 4 pups survive, it is not a breeding pair.

    If the pack is otherwise intact, but has only one surviving pup, it is not a breeding under the definition of the wolf reintroduction and delisting.

  5. caleb Avatar

    Yeah it sounds like it will be quite a bit lower this year, but i still think that my state WYO is looking for ways to kill most of the wolves outside of the parks. Even though it may be that low this year in yellowstone there have been some years where yellowstone could make up over half of the 15 breeding pairs and when you add in the ones that spend a lot of time in teton and rockefeller it is just a tiny area that the wolves will inhabit.

  6. Ralph Maughan Avatar

    I agree with you, but they have committed to providing about 8 breeding pairs.

    I suspect they might try to cheat and call a group of pupless wolves, “a breeding pair.” So, they will have to be watched, but this is hard to do because they don’t give much information.

    This should be stressed in folk’s comments

  7. John Avatar

    I feel a little sickened by the prospect of wolves being used as livestock.

  8. Jay Barr Avatar
    Jay Barr

    Somebody may want to re-examine the definition of breeding pair. What Ralph states is the “original” definition, but along the way it morphed into any 2 adult wolves with 2 pups still alive at the end of their birth year.

  9. Ralph Maughan Avatar


    I don’t believe the definition has changed, except for what they might think they can get away with.

    However, if you have a reference . . . .

  10. Robert Hoskins Avatar
    Robert Hoskins

    Let’s not forget that at one time the WGFD attempted to define a pack as 5-6 wolves traveling together, without reference to whether this traveling band was breeding and producing pups. One cannot trust the scientific integrity of G&F where wolves (not to mention elk) are concerned.

  11. salle Avatar

    “One cannot trust the scientific integrity of G&F where wolves (not to mention elk) are concerned.”

    Amen. Not only that, when I went to the hearings in Cody, (when the 10j rules were changed again and prior to the original delisting attempt), Ed Bangs said that the research would be conducted by whomever the state chooses and that only one set of observations (one study) would be needed to establish a benchmark for all cases of concern in the state. I asked what the criteria for research parameters would be or look like and he answered that the state would decide that.

    I wasn’t happy with that answer at all.

  12. Robert Hoskins Avatar
    Robert Hoskins


    No reason to be happy with that answer. I wasn’t at the Cody meeting your refer to but my friend Meredith Taylor did attend and she relayed to me the same information.

    The dishonesty of government science (with the exception of Doug Smith’s work) surrounding wolves has been one of the most galling and disappointing aspects of the entire recovery effort.

    The general practice in Wyoming for the last decade or so is for good work in the G&F Regions to be biostituted in Cheyenne before released to the public. Virtually all of the documents G&F has produced in its various petitions and lawsuits over wolves during this decade reflect a deliberate twisting of information supplied by regional biologists and deliberate misinterpretation of valid published research. I have described this process in detail elsewhere on this blog so won’t repeat it.

    There are good people in the G&F Regional Offices and quite frankly I don’t know how they stand it. Ever since the Geringer administration (1994-2002), G&F has gone from being one of the best wildlife agencies in the country to becoming one of the worst. Going into a G&F office these days is like walking into a morgue. It’s been very painful to see it happen. I don’t see things getting better.


  13. Rick Hammel Avatar
    Rick Hammel

    I am in the process of developing my comments. One issue that I am pursuing is disease. Distemper has claimed the lives of many pups over the years (40% in 1999, 19% in 2005 and I do not have a figure for 2008, but it appears to be high). Doug Smith thinks that it will grow higher as the population grows (Billings Gazette 10/25/08). Disease is a factor for listing a species under the ESA and FWS is remiss in attempting to delist while the wolf is loosing pups to distemper.

    I wonder what good the MOU is without Judge Molloy signing off on it. Is he going to buy trucking wolves around to mate or is FWS going to attempt artificial insemenation??


  14. Vicki Avatar

    I just visited WGFD’s website and it says that comments are due by November 10, not November 28.

    Am I misreading something?
    – – – – –
    The comments to WY Game and Fish are due Nov. 10. The separate comments to the federal government are due Nov. 28.
    Ralph Maughan

  15. Virginia Avatar

    There is a meeting in Cody Wednesday night, November 5 from 7:00 to 9:00 p.m. at the Holiday Inn concerning this issue. I plan to be there and speak up as I did at the last meeting – disregarding the “looks that can kill” that I encountered at that meeting. I hope to be able to present my concerns with intelligence and conviction.

  16. Ralph Maughan Avatar


    It hasn’t been proven to be distemper, but that doesn’t really matter much because the number of breeding pairs in Yellowstone presently is not higher than five and could be as few as two breeding pairs of wolves.

    I doubt the Park will ever have as many wolves again as it had at the end of last year. Figure maybe an average of 3 packs for the northern range. One for central Yellowstone. One for the south end of the Park.

    Wyoming, and the USFWS, have always assumed a much greater “contribution” of wolves from Yellowstone Park to the total number of breeding pairs in the entire state of Wyoming.

  17. Ralph Maughan Avatar


    The comments to WY Game and Fish are due Nov. 10. The separate comments to the federal government are due Nov. 28.

  18. vicki Avatar

    wow, we have two vicki’s here!!! Hi other vicki.
    Ralph, Even though I am notthe Vicki you responded to, I appreciate the info.

  19. Ralph Maughan Avatar

    Thanks for letting me know. Could each “vickie” adopt the use of a last name initial?


  20. vickif Avatar

    sure can.

  21. Wendy Avatar

    Hey Ralph, et al….

    I want to make sure I am doing this right.

    Can anyone mail comments on the proposal to Wyoming Game & Fish, as long as they are in by Nov 10th? And if so, for best results should we be referring to what is contained in the Wyoming’s Emergency Rules document and Judge Malloy’s decision?

    And as for public comments on the US Fish & Wildlife’d decision to re-open the delisting proposal (which are due before Nov 28th) we should refer to the Memorandum of Understanding and Judge Malloy’s ruling, yes? Any other documents?

    Thanks in advance. I don’t want our letters to be lost in whatever may happen once the election is over….


  22. Cindy Avatar

    I’m printing a comment card right now for the local Sierra Club office that you may find helpful. A copy of it can be found on their website, sierraclub.org. In the upper right corner under the search box click on “take action”. You can just fill out the boxes and email back to the Sierra Club who will collect them. They mention a date of November 25.
    Wolf Howls to all,

  23. Virginia Avatar

    There isn’t a current blog on this topic, so I just wanted to let everyone know that the Wyoming Game and Fish is “fishing in the dark” about this new plan. I attended the meeting last night in Cody and asked two or three questions, to which they gave me rather vague answers. When I asked about the plan to address genetic diversity or integrity – which was one of Molloy’s concerns – the G&F rep gave me a wry smile and tried to explain how they think they can try to get the wolves to cross-breed. I asked how they thought they could force a wolf to like another wolf and he said they really didn’t know. Also, I asked them after the meeting about the obvious fact that this “emergency” plan is being shoved down our throats because of Kempthorne/Bush being sent down the road soon. He pretty much admitted that it is true. The commenting period is extremely short – and, again, they admitted probably more than they should about that – so everyone needs to send their emails or fax the WY Game & Fish immediately!

  24. VickiS Avatar

    I’m the other “Vicki”. (I think we are both from CO, too?).

    My husband and I just got back from a second trip to Yellowstone viewing wolves (Great Druid watching), and our guide mentioned that the collared male Idaho wolf we saw last January who had just wandered into Yellowstone NP never did mate w/a female or join a pack. He was hanging out w/a female for a while, but they never bred.

    I find it interesting that WFGD so casually mentions in its new plan that genetic diversity can be “managed”. My comment to WFGD re: their latest “management” plan was that even if wolves manage to run the interstate gauntlet, it still doesn’t automatically guarantee genetic diversity.

    Does anyone have info on how many wolves actually make it across state lines every year, and if they do, how many actually do breed? I know every once in a while a wolf shows up here in CO, but they seem to disappear.

  25. Ralph Maughan Avatar


    They really don’t know how many wolves have traveled between Idaho/Western Montana and Wyoming (or vice versa).

    Several have been documented, including the Idaho wolf now inside Yellowstone Park. One of the Idaho wolves that went to Wyoming was illegally shot after several years.

    In Von Holdt’s genetic study of the wolves, I understand that no DNA indicating genetic mixing of the two populations was found. So if any pups were ever produced, they died, or were very rare as adults so as to probably not to be a factor.

    If I was an Idaho, Montana or Wyoming biologist, in order to pursue their state’s strategy, I would be out there testing and testing wolves’ DNA. However, they probably think their best bet is a last minute Bush Administration fix.

  26. vickif Avatar

    Yep, fellow Coloradoans.
    Wolves here do seem to disappear. I wish they could actually test the few we have confirmed sightings of, but nope….gone too fast. Ironically, DOW has film of a black wolf near Walden (a couple of sightings over the years in that area, yet we have no on going presence, despite the favorable conditions)…and they could only keep track of him for ‘seconds’. I guess he hid amongst the cows.
    One was sighted in RMNP, I got photos of rather large paw prints in the snow, but I am no expert. Yet, rangers denied the sighting, and the wolf was gone as fast as it was spotted, in a national park where tracking should have been easy.
    Perhpas our new democratic majority will help find better ways to ‘manage’ roaming wolves.


Dr. Ralph Maughan is professor emeritus of political science at Idaho State University. He was a Western Watersheds Project Board Member off and on for many years, and was also its President for several years. For a long time he produced Ralph Maughan’s Wolf Report. He was a founder of the Greater Yellowstone Coalition. He and Jackie Johnson Maughan wrote three editions of “Hiking Idaho.” He also wrote “Beyond the Tetons” and “Backpacking Wyoming’s Teton and Washakie Wilderness.” He created and is the administrator of The Wildlife News.

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