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,\
\
Our SaveElk Coalition represents a group of concerned Idaho Sportsman
asserting the rights and prerogatives of hunters and sportsman. Most of
our members (currently numbering in excess of 800) were initially
opposed to the \"introduction\" of the non-native Canadian Gray Wolves
into Idaho; however regardless of our earlier objections we recognize
that the introduction has been a huge success and that these Canadian
wolves are here to stay. We support and request their immediate
delisting as an Endangered Species animal and for them to be
reclassified as a big game animal, with related management transferred
to the respective states of Idaho, Montana and Wyoming. Below are more
specific comments that we wish to provide for consideration.

**[Population far exceeds original agreed level]{.underline}**

Since the original introduction into our state, the population of the
Canadian Gray wolves has exploded with population estimates exceeding
1200 wolves in Idaho, and over 3000 Wolves in the States of Idaho,
Montana and Wyoming (per Dr. D Mech testimony at Judge Malloy trial).
This dramatic wolf population expansion is further being propelled by
high fertility rates and abundant food source which is netting an
estimated net annual population increase of 20-30% depending on the
territory. Our ungulate game population cannot possibly withstand this
continued wolf onslaught, with several areas throughout our state
already experiencing significant ungulate depredation due to wolves. Of
particular concern to our group is that the current estimated 1200
population level of wolves exceeds the original agreed upon plan level
of 150 wolves by 800 times! The original wolf population level
advocating a maximum of 150 was widely publicized by the USF&W as the
ultimate population goal. This level was the basis for acceptance by the
public and for the development of our state's Wolf Management Plan. This
WMP was acknowledged and accepted by all parties and organizations
involved in the wolf introduction effort, which included negotiations
and consent from all groups including pro-wolf, anti-wolf and general
citizenry. The plan was endorsed with the understanding that a maximum
level of 150 wolves could be tolerated before inflicting adverse harm
and depredation to our state ungulate herds. The 150 wolf population
level was the basis used throughout the original negotiations and was
supported and promoted by the USFW Service, and was the basis for which
the Idaho State legislative committee approved the final Idaho Wolf
Management Plan. It was this agreed upon plan that was granted final
approval by the USF&W -- US Dept of Interior, and was the premise and
condition used by all parties in agreeing to the initial wolf
introduction, and in the final wolf delisting proclamation. It is our
contention that the USF&W Service has entered into a contract with our
state(s), we have complied with our terms and requirements, and it is
incumbent on the USF&W Service to follow through with their commitments
including their promise to delist. It is our contention that continued
listing of wolves will inflict significant irreparable harm to the State
of Idaho and its citizens, and will be cause to declare the Idaho Wolf
Management Plan "contract" with the USF&W Service broken, and for the
contract to be declared null and void.

**[Unacceptable Ungulate and Livestock Depredation]{.underline}**

The current environment, in which wolves are not being managed and are
allowed unconstrained population growth, is significantly jeopardizing
the continued viability of our states ungulate herds, with wolves
depredating ungulate throughout our state and totally eradicating elk
herds in some isolated areas. This will result in continued irreparable
harm and duress to our state and its residents from wolf inflicted
damages resulting in lost hunting and outdoor revenues; and will
continue to cause significant and irreputable harm to our sportsman,
hunters and citizens who depend on vibrant surplus game populations for
their livelihood and for enhancing hunting opportunities. The argument
that the economic damage and loss of commerce from reduced ungulate game
will be eventually abated from increased revenues by wolf "sightseers"
is absolutely wrong and totally misguided. Such additional revenue would
be minuscule in comparison to the significant losses to our state from
the resulting lost commerce from hunting and sportsman. Allowing the
continued depredation of our prized big game ungulates by these wolves
will result in grave long-term negative consequences to our state. Our
State, our States' Fish and Game Department, and a significant number of
our states' residents depend on the commerce generated from maintaining
vibrant, healthy big game herds. Further, these wolves are causing
significant harm to ranchers by inflicting ever increasing livestock
losses. Many growers are never adequately compensated for their losses
due to the red tape involved, and from the inability to directly connect
livestock kills to wolves. Many of them are being driven out of business
due to this continued wolf caused harassment and resulting livestock
losses.

**[Genetic diversity]{.underline}**. 

We object to the Genetic Diversity and Connectivity argument which was
used as a primary reason by Federal Judge Malloy in his decision to
order continued listing of wolves. We assert that this condition was not
required or mentioned in the original EIS and was not a criteria
requirement for the eventual delisting of wolves. This argument was
raised "after the fact" and apparently was only brought up and mentioned
as a significant requirement in the recent delisting hearing. Since it
had not been recognized as a requirement, the defendants were caught off
guard and were ill-prepared to adequately address this "phantom"
requirement. 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
reasonable scientific basis or fact, and is contrary to all known
behavior and instinct of these Canadian wolves.

This argument has been misconstrued and does not consider the extreme
territorial behavior of these transplanted wolves, and the fact that
wolf packs establish territories and will kill any foreign wolves from
other packs entering their territory. Further, those involved in animal
husbandry acknowledge that genetic diversity is not a prime requirement
for the establishment of healthy animal populations. In fact most
believe the opposite is necessary to establish healthy genetics and long
term species sustainability. Most animal breeders concentrate bloodlines
in order to produce desirable traits in offspring, and do such without
any species degradation.  This practice has occurred 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**.]{.underline} 

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**. ]{.underline}

Another concern with this wolf introduction and continued lack of
management is that it is commonly known that wolves are susceptible to
and transmit several diseases. The EIS never adequately addressed the
issue of wolf transmission of disease and parasites, which may adversely
affect domestic animals, other wildlife, and people.

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.\
[\
**Canadian Gray Wolf is not the native wolf and has eradicated the
native wolves**]{.underline}. 

A further concern is this introduction of the non-native Canadian Gray
wolves into Idaho and the Northern Rockies is the affect they had by
eradicating the existing native "Timber Wolf"; which in itself makes the
release of the Canadian Gray wolves into our state a violation of the
Endangered Species Act.

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 Idaho, Montana and Wyoming; and then the release
of the Canadian subspecies was an overt violation of the Endangered
Species Act.

**[Summary]{.underline}**

Regardless of our position on the legality or illegality under the ESA
for introducing the Canadian Gray wolves into Idaho, we acknowledge that
they are here to stay. We recognize that the growth in wolves and the
current population levels vastly exceed all stated and acknowledged
population goals and objectives. Therefore we urgently request that
these wolves be immediately delisted and we support the transferring of
their management to the State of Idaho. It is our position and belief
that this is the most prudent and scientifically based approach to
protect and manage this wolf species, and guarantee their long term
viability within our state.\
\
Sincerely,\
\
Tony Mayer

Co-Founder, SaveElk Coalition