Wolf Discussion Absent from Idaho Wildlife Services EA

Idaho Wildlife Services recently made public an Environmental Assessment (“EA”) supposedly analyzing statewide predator damage and conflict management. However, wolves are notably absent from the 273-page document. Wildlife Services’ recent killing of five wolves in central Idaho—in addition to previous killings of six in response to livestock depredation and 19 to boost elk populations in the Lolo zone—should cause the public to question the exclusion of a discussion about wolves from the new EA.

The EA says that wolves were not addressed because Wildlife Services already completed a separate EA specific to wolves in 2011. Superficially, the exclusion appears to be a sensible decision to avoid lengthening an already lengthy document. When considered side-by-side, however, the two EAs fail to account for the full spectrum of the effects of predator management.

Mesopredator Release and Trophic Cascades

Decline, extirpation, or reintroduction of wolves can cause “trophic cascades,” whereby lower trophic level populations experience drastic changes following alterations to an apex predator population. The decline of apex predators can affect disease dynamics, wildfires, carbon sequestration, invasive species, and even landscape features such as rivers.

Apex predators “suppress” mesopredators through intraguild predation (i.e. wolves killing coyotes) or resource competition. When apex predators decline or go extinct, mesopredator numbers can drastically increase, a phenomenon called “mesopredator release.” Though the theories have not attained full consensus among biologists, the body of supporting research is growing.

The wolf EA does mention trophic cascades in Yellowstone National Park following wolf reintroduction—but only in the section titled “Issues Not Considered in Detail.” Wildlife Services cited one study from 2004 focused almost entirely on aquatic ecosystems and one book chapter from 2005 by the same scientist that briefly noted that few studies existed on wolf-ungulate-vegetation trophic cascades over areas larger than Yellowstone National Park and Isle Royale. However, enough studies have been published since 2005 for Wildlife Services to meaningfully assess the ecosystem effects of lethal wolf management.

With respect to coyotes, the wolf EA discussed only the direct effects of wolves, citing one study from 1999 and one book chapter from 2003. The EA did not mention other recent research on intraguild predation and indirect effects of wolves on coyotes.

The new statewide EA does mention trophic cascades, again in the section titled “Issues Not Considered in Detail.” Once again, Wildlife Services has chosen not to analyze in detail the potential effects of lethal predator control on other predators, prey, and vegetation. And because this EA completely excludes any discussion of wolves, Wildlife Services still has not analyzed how lethal wolf management affects mesopredators and prey. In light of the fact that the preferred alternative seeks to expand predator killing to protect game species—including non-native species such as the ring-necked pheasant—Wildlife Services desperately needs to conduct a meaningful and transparent analysis of the ecosystem effects of the lethal control of wolves.

Wolf Killing Might Not Reduce Livestock Depredation

A groundbreaking 2014 study seriously undermines the practice of “remedial control” of wolves in response to livestock depredation. Contrary to conventional wisdom, the study concluded that lethal control actually increases livestock depredation the following year. Each additional wolf killed increased the both the mean numbers of sheep and cattle depredated. Yet because this study was published after the wolf EA was finalized and the statewide EA excludes wolves, wolf control does not account for this finding. So, why does an agency whose mission is “to provide Federal leadership and expertise to resolve wildlife conflicts to allow people and wildlife to coexist” choose to blindly adhere to practices that are bad for wolves and the economic interests of private livestock producers for whose benefit predators are killed to protect?

Idaho Wildlife Services Should be Held Accountable to Idahoans

The National Environmental Policy Act requires federal agencies to analyze the direct, indirect, and cumulative effects of their actions. A cumulative impact results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions taken by any agency (federal or non-federal) or person. Clearly, the analysis of statewide predator damage management should include a discussion about wolves.

Wildlife Services cannot ignore the actions that have been, or will be, taken by it and other agencies. Wildlife Services is already killing wolves in an attempt to protect livestock and increase game populations (i.e. elk in the Lolo zone). The Bureau of Land Management, a federal land management agency, has permitted a private group to hold a wolf and coyote derby on public lands for the past two years.

Idaho Fish and Game Commission first voted to allow the hunting and trapping of wolves in 2009, the year that US Fish and Wildlife Service removed Endangered Species Act protection of wolves in Idaho. Commissioner Brad Corkill said, “If every wolf in Idaho disappeared I wouldn’t have a problem with it” at his Senate confirmation hearing last year. Unsurprisingly, Idaho’s year-end wolf population dropped from 856 in 2009, to 777 in 2010. Between 1995 (the year of wolf reintroduction) and 2008, the wolf population steadily increased. With the exception of 2014, wolf populations declined each year since 2009. At this time, we can only speculate whether last year’s population increase was a fluke. However, the new Wolf Depredation Control Board exemplifies the state’s increasingly aggressive attitude toward the native apex predator.

Express Your Dissatisfaction with the EA

As a federal agency, Wildlife Services is required to consider and respond to all public comments. Thus, Wildlife Services cannot simply ignore public outrage at the inadequate EA. If you have not already done so, you still have time to submit comments on the draft EA. The agency, which Congressman DeFazio calls “one of the most opaque and least accountable” federal agencies, should not continue to use our tax money to kill native predators on public and private lands for the benefit of concentrated interests.


  1. Ida Lupine Avatar
    Ida Lupine

    I’m speechless. 🙁

  2. ramses09 Avatar

    Ditto Ida.

  3. rork Avatar

    “A groundbreaking 2014 study seriously undermines”
    You are scared to discredit yourself I see.

    1. rork Avatar

      Aren’t, durn.

  4. Joan Avatar

    How does Commissioner Bill Corkill think he and Idaho residence will last in this land he so wants to destroy. If wildlife services fail to report all data found what else are they failing to disclose. As long as we have plenty of game for those oversized gun slinging pathetic people called Game Hunters they will deplete themselves. Put that in a report. Apex Pretators are the most important means to natural survival. This way of acting is irreversible and when there is no Trophic Cascade there will be no game to hunt cause of disease & Mans own destructive behavior. Survival of the fittest and Wolves will out live us all!!

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Barrie Gilbert