Comments by the major groups on wolf delisting

Did they do a good job?

The comments seem extremely strong to me. The comment period on the latest run at delisting ended on Nov. 28. This blog is probably the only place you will find these comments on-line all in one place.

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NRDC-comments-wolf-delisting-nov28-2008 Pdf file

Earthjustice for 14 groups-nov26-2008 Pdf file

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Added 12-2. Comments by Idaho in favor of delisting. Pdf file.



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  1. Salle Avatar

    I think they did a great job presenting the arguments. It can only be disputed if one thinks like George Bush or Dick Cheney, not a lot of clarity or actual intellect need there!

    I hope that someone will recognize the facts here. Probably have to wait until after Jan. 20th though since there is nothing but raping and pillaging going on in the White House until then. Vandalism at the highest level in the halls of government… And the Judge Roy Bean school of thought, or was that Jethro Bodine?

  2. Rusty Avatar

    Their comments were a lot better than my “you are all idiots” comment I submitted.

  3. JEFF E Avatar
    JEFF E

    don’t feel bad.
    It probably is better to go with the “your all Idiots” rather than the converse as displayed by this submission. (citation on request)
    “U.S. Fish and Wildlife Service Western Gray Wolf Recovery Coordinator 585 Shepard Way Helena, Montana 59601

    Comment — Canadian Wolf Delisting and Designating the Northern Rocky Mountain Population of Wolf as a Distinct Population Segment

    Dear Sirs,

    The *******(sic) Coalition is a group of concerned Idaho Sportsman asserting the rights and prerogatives of hunters in Idaho. Most all of our members (currently numbering in excess of 800) were initially opposed to the initial “introduction” of the non-native Canadian Wolves into Idaho; however concurrently we recognize that regardless of our earlier objections we recognize that these wolves are here to stay and we support the immediacy for wolves to be removed from protection as an endangered species, and for the immediate classification as a big game animal and for the immediate transfer of management of this species to the state of Idaho.

    It is our position that the population of these Canadian wolves has exploded within our state multiplying at an annual rate of 20 to 25% since the original introduction. Current estimates far exceed 1000 wolves. This population is 6,666 times the original agreed upon 150 maximum wolf population levels that was acknowledged and accepted in our state wolf management plan, which was widely publicized, acknowledged and accepted by all parties involved including pro-wolf, anti-wolf and general citizenry. This was the basis and plan that was finally approved by the USF&W Service and the Federal Government as a condition of wolf delisting. Continued lacks of wolf management and unregulated and unconstrained wolf growth is significantly harming and reducing our state ungulate herds, with wolves have totally eradicated elk herds in certain isolated parts of our state. Continued listing of wolves will cause irrefutable harm to our states residents in lost hunting opportunities and in lost tag revenues, with the resulting loss of commerce that many citizens depend on for their livelihood. The argument that wolf sightseeing will offset this loss in commerce is absolutely wrong and totally misguided. A significant part of our state commerce depends on maintaining vibrant, healthy big game herds which are being significantly harmed by the unregulated growth of these wolves. Further livestock growers are experiencing continued harassment and herd losses from wolf depredation with many entities being driven out of business.

    Further, this wolf introduction has never adequately addressed the issues of wolf transportation and transmission of disease and parasites that may affect people, domestic animals and other wildlife. It is commonly known that wolves are susceptible and transmit several diseases.

    Finally, it is our testimony that the introduction of the non-native Canadian Grey wolves into the Northern Rockies has eradicated the already-existing native “Timber Wolf” that was living here; making the release of the Canadian wolves into our state a violation of the Endangered Species Act.

    Genetic diversity. We wish to object to the Genetic Diversity and Connectivity argument used as a reason for the Federal Judge to disallow the delisting of wolves in our state. We assert that this specific condition were not required under the original EIS and was not a requirement for the eventual delisting of wolves under the Endangered Species Act. The argument that “genetic diversity” and “genetic connectivity” of wolf populations must be assured before wolves may be delisted in the northern Rocky Mountains is unreasonable, lacks any reasonable scientific basis or fact, and is contrary to the practiced behavior of wolves.

    This topic is misconstrued and does not consider the extreme territorial behavior of these transplanted wolves and the fact that packs establish territories and kill off any intruders from other packs. Further, those involved in animal husbandry acknowledge that genetic diversity is not any sort of prime requirement for the establishment of healthy animal populations. In fact most believe the opposite to establish healthy genetics. Many animal breeders actually concentrate bloodlines in order to produce desirable traits in offspring, without any species degradation. This practice has been practiced since the beginning of modern man as we know it.

    In addition, scientific testimony was presented in the lawsuit in federal court to reverse the previous delisting effort to document that some populations of wolves begun in isolated location(s) with only one male and one female, and with no additional injection of genetic material, are thriving – that lack of genetic diversity is no handicap to species survival whatsoever.

    Further, the Canadian wolves that were released in Montana by the USFWS were drawn from several different parts of Canada, giving that released population a genetic diversity base far exceeding that necessary for a healthy population.

    Actual practice and historic observation inform us that the only genetic diversity issue of any real consequence whatsoever is that there be both males and females. Once that diversity threshold is achieved, all rational genetic diversity needs have been met.

    Those who advocate genetic diversity have offered no proof that genetic diversity among wolves is either desirable or necessary. If genetic diversity is so important, why has it taken wolf advocates over a decade to discover and articulate it? Why was argument for genetic diversity not made when the Endangered Species Act was crafted, or when the several state wolf management plans were devised? If the argument of genetic diversity has been apparent to the wolf advocates for a decade but they have deliberately not raised it until the 11th hour could that long silence be a type of fraud?

    Genetic diversity is a thin, ruse argument. It is grasping at straws. Anyone who claims merit in that argument is either agenda-driven or using the argument as a façade. We also assert that there currently exists sufficient “genetic diversity” and “genetic connectivity” of Northern Rockies wolf populations to pass any rational, unbiased test. We assert that wolf advocates had years to raise these issues, but either slept on their rights or committed fraud though deliberate silence.

    Genetic connectivity. This argument is also a ruse. First, wolves’ social makeup is strongly antagonistic to genetic connectivity. Wolves regularly and reliably kill other wolves, with other genetic makeup, that stray into the area claimed by a pack. So, wolves actively resist genetic connectivity, no matter how much nature-loving environmental activist’s wish it was otherwise.

    Second, without need for genetic diversity, as discussed above, there is simply no need for genetic connectivity.

    Third, there is already a potential for genetic connectivity that is probably an order of magnitude greater than anything that might be required for a genetically-stable population. For example, a few years ago a wolf collared and released in Montana was found as road-kill in Texas. This wolf had traveled an incredible distance.

    There are three populations of wolves discussed in the Northern Rockies; the population migrating from Canada in northwestern Montana, the population introduced into the Yellowstone Park area, and the introduced population in central Idaho. There are documented wolf packs west of Missoula, both north and south of Interstate 90; an area that is roughly equidistant from the three general populations mentioned proceeding. It is axiomatic to presume that the wolves west of Missoula came from one of the other three surrounding wolf population centers. Ergo, if wolves can reach the center of the existing population triangle, wolves are then quite capable of reaching any part of the triangle from any other part of the triangle. To say otherwise is to defy rational thought.

    If there is inadequate intermingling of wolf genetics (according to some), it is mostly because wolves kill strange wolves at the first opportunity. Perhaps the advocates of genetic connectivity ought to be assigned the task to force the mating of wolves strange to each other (sorry, no protective clothing or protective devices allowed). Let’s get on the record just how well wolves tolerate that.

    Wolf advocates have long known the terms of delisting. Those objecting to delisting had years to raise new issues concerning delisting, but they never did. They cannot claim ignorance of pending delisting. There have been multiple opportunities to raise new issues in comment on state management plans, listing and delisting, yet genetic diversity and genetic connectivity have never before been central to the wolf advocates’ position.

    Disease and parasites. Precious little attention has been paid to the diseases and parasites for which wolves may be vectors. Wolves are certainly hosts to or potential vectors for many dangerous diseases and parasites that affect other wild animals, livestock and humans, e.g. distemper, rabies, anthrax, brucellosis, echinococcus granulosis, and others. Because wolves are so highly mobile, their role as vectors is a huge liability to other species also subject to the diseases and parasites they may carry. Therefore, the potential exists for wolves to have a vast and incalculable negative impact upon other species, domestic, wild, and of course, humans. The liability associated with far-ranging wolves as disease and parasite vectors argues strongly for wolf delisting and comprehensive wolf management.

    Eradication of native wolves. In her book Yellowstone Wolves, Kat Ubrikit makes a compelling case that a separate subspecies of wolves inhabited the greater Yellowstone area, including Montana and Wyoming, than the subspecies of Canadian wolf released by the FWS. This subspecies looks different, has different social structure, and hunts differently. There is a history of far too many documented sightings of this native subspecies for there to be any rational doubt that it existed prior to the release of Canadian wolves. Facing the near-certainty that this native subspecies existed and inhabited Montana and Wyoming, and then the release of the Canadian subspecies was an overt violation of the Endangered Species Act.

    For the above reasons and arguments regardless of ones position on the legality of the illegality under the ESA for introducing the Canadian Grey wolves into Idaho, we acknowledge that they are here to stay and we highly support and encourage the immediate delisting and transferring of management of wolves to the state of Idaho. We believe that this is the only prudent way to allow our state to manage this species to guarantee their long term viability within our state.”

  4. Salle Avatar

    How much d’you wanna bet that the above submission was based on that stupid MOU that Ron Gillette and Lenore Barrett submitted to the ID legislature?

    It sounds just like Gillette’s stupid claims that he has been spewing all these years… only I’m sure someone else actually wrote it since Gillette isn’t capable of composing a proper sentence. Maybe they had help from Sarah Palin.

    Ignorance is their strongest suit.


  5. IzabelaM Avatar

    I go with Rusty. They are all idiots.

  6. Salle Avatar

    Me too.

  7. Chuck Avatar

    You know I would like to send Ron Gillette to be on that show “Are you smarter then a 5th grader” his stupidity amazes me.

  8. JEFF E Avatar
    JEFF E

    FYI Ron Gillette was not the author of the above submission although I would imagine something very similar but I do believe Gillette has a much better basic education than what is displayed above.
    I just do not want to provide this author with any free advertising if I can however it is word for word copy.

  9. John d. Avatar
    John d.

    Oho boy that author went to great lengths, let’s give him/her a A+ for the effort that it took to cover all the argument bases… and give an F- for subject accuracy.

  10. Brian Ertz Avatar

    These comments are wonderful – I learned a lot about the particular issues involved and about wolf biology and genetic viability.

  11. Peter Kiermeir Avatar
    Peter Kiermeir

    This never ending canadian wolf tragicomedy…….. It nerves! I fully support the summary of the epistle: “you are all idiots”.

  12. Salle Avatar

    That set of comments might get an A+ for effort, certainly it took a long time to write all that swill in a form that can be read but it surely loses the argument when it comes to “science-based” information, hands down!

    Rusty made the right call.

  13. vickif Avatar

    Idiotic as they are, and moronic as Gilette and Barret may be, they are not alone. They must have been those kids that burned their right hands on the stove and then went back and burned the left one-when given specific and irrefutable evidence tthey should learn from they are too dense to absorb it or comprehend it…
    or perhaps they are just intellgenet enough to figure if they keep spewing their line of crap their babbling could confuse people into believing them. Therefore they attempt to selfishly prosper no matter the harm or deceit it creates.

    Most of us here could ramble off arguments to counter the above ‘author’s’ insufficient and innaccurate statement….but it is far easier to just convincingly shake our heads in condesention and proclaim loud and clear “THEY ARE ALL IDIOTS”! I couldn’t agree more!

  14. Jon Way Avatar

    If the 1000 estimate is 6,666 times what should be there, then rough math indicates that they claim there should be a 1/6 of a wolf (yes, one-sixth) to be recovered. Interesting claim.

  15. Salle Avatar

    It’s pretzel logic and fuzzy math…

    Soon to be a thing of the past in policy-making, I hope.

  16. Laura Avatar

    I am having mixed feelings about the example Jeff E posted. On one side if this is a representative example of the pro-delisting comments that were sent in then it would be hard to take the garbage seriously-good news for those of us who want the wolves to stay listed. On the other hand, knowing that so many people actually believe the garbage is disheartening and bad news for the pro-wolf folks (but I have read enough here and on other sites to know the reality of the situation).

  17. DA Avatar

    “This population is 6,666 times the original agreed upon 150 maximum wolf population levels”
    Good Lord! Based on traditional math (these fellows may use some new kind) this is nearly 1 million wolves. I had no idea wolves were doing so well in Idaho!

    And you are right Laura – “knowing that so many people actually believe the garbage is disheartening and bad news for the pro-wolf folks” — that’s the larger, more painful picture isn’ it?

  18. caleb Avatar

    DA, Your math is right i noticed that and did the math when i read it and it comes out to 99,990 wolves according to those idiots. And i checked out the lady “Cat” that they quote and who sued saying there was a subspecies of yellowstone wolves already in the park is of course they just happen to be sheep ranchers.

  19. Barb Rupers Avatar
    Barb Rupers

    I thought the math a bit fuzzy myself; decided they used a comma instead of a period. 6.6666 x 150 = 999.99 and they claim >1000.
    Partial wolves, one sixth, or a popultion that might cause a bit of a problem, 999,990!

  20. Salle Avatar

    Since there are certainly not 999,990 wolves in Idaho, or the entire continent for that matter, I would guess that the 1/6 tally would be a far greater reason for continued endangered status for quite some time and with no lethal control of any kind.

  21. John d. Avatar
    John d.

    IDFG is acting very confident this year, its drawing up a wolf hunt even before the decision is made. Low and behold its the same ‘kill as many as we can’ attitude.

  22. vickif Avatar

    John d.Suprise, suprise. How could we have ever presumed to have known the attitude would remain the same even when a judge pointed out the flaws of delisting criteria?Anyone, this “Cat”, came to have so much wolf DNA in order to do this fact based scientific research how? She must be a biologist? Or even better, a sheep rancher because that makes her far more qualified to asses the entirety of reintroduction. After all Dr. Doug Smith might need to be up dated…sheesh. Come on!!!!! SOme one please tell me what makes this Cat the authority on all things canid?Doug Smith has stated “In areas that are heavily ‘agriculturalized’, we shouldn’t have wolves. They should just be killed. And on the flip side, in wild land areas, like national forests,wilderness parks, and wildlife refuges, we should vigorously protect wolves and other carnivores. The tough part becomes the attention zone in between.”

    This statement identifies they key problem with conservation in it’s entirety. We have failed miserably at keeping the national forests nation….they have become agriculuralized. If we were to remove livestock from public lands, we would have far more opportunity to conserve the “wild” in our environment.
    The attention zone….the in between, should be the only grey area. The places where the ag industry is in the center of development should be maintained wolf free. The suburbs and developments where people have built themselves into the habitat, is not that area. The national forests and land bordering them should not be either.

    Doug Smith has also talked about the various factors of “loss” that ranchers feel. Among them, he talks about higher costs to have range riders to patrol their cattle. Perhpas we should stop compensating inflated amounts of money for livestock losses and introduce a new plan to provide funds to pay for (or have volunteers) riders to watch over herds that are grazed entirely on private land. Frankly, if grazing occurs on public lands, the public’s ownership over those lands and inhabitants trumps the value of livestock predated upon-no compensation should occur.

    We need to face it, and put a stop to it, the delisting needs to occur with specific outlines to address what wolves are to be placed in jeopardy, and where. It needs:
    1. scientific regulation based on a national population and not a state population to determine how many wolves can be hunted upon delisting,
    2. a well defined criteria, and checks and balances to assure the integrity of the process of mortaly managing wolves,
    3. a plan to remove livestock from public lands, and failing that, a law that makes losses of livestock on public lands non-compensatable. There should never be lethal management of a wild animal on public lands unless the animal is a clear and documented threat to human safety. (that should also spill over into management of bison based on bogus burcellosis hype-and should lead to their listing as wildlife and not agriculture. Wild bison are not domesticated cattle!)

    The groups that speak up are doing good deeds, but we have all got to speak up to make sure the laws reflect the welfare of the interests of the general public, and that should be based in science and not emotion. Then we will have to fight damn hard to make sure those laws are aggresively enforced.

  23. vickif Avatar

    after thought, we should also have a federal mandates on how predators are hunted, when, and how much tags cost. That might mean changing some laws, but it would assure an even playing field for wolves, and all predators.

  24. Layton Avatar

    John D. said this:

    “IDFG is acting very confident this year, its drawing up a wolf hunt even before the decision is made. Low and behold its the same ‘kill as many as we can’ attitude.”

    Just in case any of you folks here would be interested in a bit of truth with your morning dose of hyperbole — here is what the Idaho F&G website has to say — please note the last paragraph. (sorry, I don’t know how to put a link in on this site — here it is in plain text

    “Idaho Wolf Management
    Federal Protection Reinstated for Idaho Wolves – On July 18, 2008, Judge Donald Molloy of the U.S. District Court in Missoula issued a preliminary injunction that returned the wolf to federal endangered species protection.

    The injunction was sought by parties to a lawsuit challenging the U.S. Fish and Wildlife Service’s decision to remove gray wolves in the Northern Rocky Mountains from the endangered species list.

    On October 14, Molloy filed an order granting the United States’ motion to remand the delisting rule back to the Fish and Wildlife Service. He also dismissed the case. The U.S. Department of Interior and the Department of Justice are reviewing options and believe the remand was the most expedient way to address the courts concerns and to delist wolves.

    On October 24, the U.S. Fish and Wildlife Service reopened the public comment period on its proposal to delist the gray wolf in the northern Rocky Mountains. In a notice published in the Federal Register October 28, Fish and Wildlife asked the public to comment and provide any additional information on the February 2007 proposal to delist wolves. Fish and Wildlife was seeking additional information on a variety of topics related to the delisting. More details are available in the Federal Register notice which will be posted along with associated materials at the Fish and Wildlife Service’s Northern Rocky Mountains Wolf Website

    The hunting season in Idaho is on hold and no wolf tags will be sold until wolves are delisted. Read Fish and Game rules and state laws on hold pending litigation and until wolves are delisted.”

    I’ve noticed several other folks pointing out that “Idaho F&G wants to kill them all and they are coming up with a season even though it’s illegal” — c’mon, try a little bit of honesty— Just once!!

  25. Layton Avatar

    Cool, the link came through.

  26. Layton Avatar


    Just FYI, the only animals in Idaho listed as “predators” and therefore unprotected, are Coyotes (that won’t make Jon Way happy) skunks, weasels and jackrabbits.

    All other wildlife IS treated the same way, subject to regulations, tags, and the whole bit.

    Also FYI, wildlife within state boundaries is (after many court cases) managed by state regulations — except migratory critters like ducks, doves, etc. Or do you propose managing ALL wildlife under federal rules??

  27. vickif Avatar


    “I’ve noticed several other folks pointing out that “Idaho F&G wants to kill them all and they are coming up with a season even though it’s illegal”- c’mon, try a little bit of honesty-Just once!!” Where are those several other folks comments? I only saw it mentioned once, so just asking.

    The person who did mention it seemed to be pointing out, more specifically, that it didn’t seem to differ from the previous plan, in his opinion. Which I found the primary focus…but just my interpretation. So if it doesn’t differ much, what would you change?

  28. vickif Avatar


    Maybe. If all predators were regulated under federal guidelins, we would have more consistency in interpretation of the law. It seems like oe big stumbling block through all of this is the differences in each state’s proposal.

    I am aware that hunting (excepting migrating birds) is regulated on a state level now, but I just wonder if maybe it shouldn’t be managed more like migratory birds. Maybe itshould be an issue of managing all predators for what is optimal to species as a whole, and not just in one area? Especially given the fact that we now have wolves dispersing to other areas (WA, OR). Shouldn’t we be looking at how to see the bigger picture? How could we encourage , through management, a more even dispersement of packs, less saturation in certain areas? How could we assure that state’s participate in management on an ethical and even level? ( Therefore providing for appropriate dispersing of funds for management.)

  29. Layton Avatar


    “So if it doesn’t differ much, what would you change?”

    I’m making the assumption here that you are talking about the plan for a wolf hunt in general — right?? NOTE: AFTER the wolves are de-listed!!

    If that’s the case, from what I’ve seen of it, I wouldn’t change much. I don’t subscribe to the “it’s a kill ’em all plan” theory that seems to come up every time even taking a few wolves out is mentioned. IMNSHO we have to many wolves in the state now and I think we need to control the numbers statewide.

    I do think that Idaho can manage the wolves successfully and I don’t believe that with the eyes of the “wolfies” nation wide on F&G that they would screw it up — despite what a lot of people here believe. I also DON”T think there is some great, dark, deeply buried conspiracy between the livestock folk and the F&G to eliminate wolves in their entirety.

    As far as federal control of hunting —- are you kidding!! First of all, how does some official from (for instance) Ohio have any kind of an idea about wildlife requirements in Idaho or Washington?? How does someone that is very familiar with things in Oregon or Montana come up with a reasonable method of managing Whitetails in Georgia??

    Naaaa, I just see that as another federal boondoggle with the possibilities of screwups being rampant. I don’t see how there can be any sort of even disbursement of funds OR critters between different parts of the country. The wildlife is different, the needs are different, the habitat is different and I don’t see much possibility of a cohesive strategy happening. Just my opinion — but everyone has one of those — right??

  30. vickif Avatar


    You used to bug the sh*t out of me. Now I get a kick out of you, I admire your spunk and appreciate you responing with civility and conviction.

    If you don’t think Idaho will screw up because wolfies are watching, I’d say history has proven the contrary. They don’t give a hoot about actual opinions of people outside of their campaign contributors and rancher buddies. Though I know some F&G guys do, but legislators…not so much.

    As far as a conspiracy, no conspiracy….livestock interests as a whole are to completely get rid of wolves, and I don’t think they hide their desires much. F&G, well that depends on their loyalties as individuals—their duty under the law, or their allegance to certain groups. That makes them human, right?

    How does some official from another state have any idea about wildlife in another state? Well, science Layton…the same way you would have knowledge about the elk in Idaho if you were from Wyoming, scientific information and data. But if we use your arguement, how can I trust some guy from Wyoming to manage a national resource? Like wolves or even water, or voting about my rights if he lives in another state? We need to keep in mind that federal rights out weigh state rights, for good reason. This country is operated off of tax dollars contributed by every American, not just those in one state or another.

    Like it or not (my guess is not), this is about more than making a state’s people happy, it is a national issue and deserves national representation. Without it, you will never have any degree of public satisfaction or resolution.

    If you level it all out, you will end a lot of bickering.

    I can see the concern about a federal boondoggle. I also know critters differ, but they are always interdependant for survival. How they live may change based on their immediate ecosystem, but their basic needs don’t….habitat, food, water, ability to sustain gentics and populations. So managing the species is a possible idea, and as good as managing a state. Wolfies may not have perfected this, but the states (WY, MT, ID) have sure fudged up too. Federal screwups are no more rampant that state screwups, neither are endangered.

    There could be an even dispersement of funds, or atleast one based on scientifically estimated populations, so funding could be based on how many wolves are located in each state, and what needs to be done to sustain future populations naturally occuring in other states.

    Heck, I don’t have all the answer. But this state based regulation just ain’t cutting it in the eyes of our nation.

    Just my opinion…and everyone does have one, lol. Have a good day Layton!

  31. JEFF E Avatar
    JEFF E

    It appears that the comment period was just a going thru the motions exercise.


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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