Environmental Assessment

Wildlife Services

Gray Wolf Damage Management 

In Washington

Lead Agency: U.S. Department of Agriculture

Animal and Plant Health Inspection Service 

Wildlife Services

August 20, 2014
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington i

Table of Contents

List of Acronyms and Abbreviations........................................................................................................................... iii

EXECUTIVE SUMMARY ..........................................................................................................................................iv

CHAPTER 1. PURPOSE AND NEED FOR ACTION................................................................................................1

Introduction ...............................................................................................................................................................1

1.1 Purpose ................................................................................................................................................................4

1.2 Need for Action ...................................................................................................................................................4

1.3 Scope of Analysis – Location and Actions Analyzed..........................................................................................7

1.4 WDFW Wolf Management Goals .....................................................................................................................10

1.5 Period for which this EA Remains Valid...........................................................................................................11

1.6 Decision to be Made ..........................................................................................................................................11

1.7 Summary of Public Involvement Efforts...........................................................................................................11

1.8 Relationship of this EA to other Environmental Documents.............................................................................12

1.9 Authority and Compliance.................................................................................................................................13

1.9.1 Authority of Federal and State Agencies in Wolf Damage Management...................................................13

1.9.2 Compliance with Federal and State Laws, Policies and Executive Orders.................................................14

CHAPTER 2. DESCRIPTION OF ALTERNATIVES ..............................................................................................18

2.1 Alternative 1 - No Action ..................................................................................................................................18

2.1.1 Non-lethal Methods Available to WS, WDFW, USFWS, Tribes, and the Public ......................................21

2.1.2 Non-lethal Methods Available to WDFW, USFWS, and Tribes, but not WS............................................23

2.1.3 Non-lethal Methods which may Require Special Authorization from WDFW, USFWS, and Tribes........24

2.1.4 Description of Lethal Methods Available to WDFW, USFWS, and Tribes, but not WS ...........................25

2.1.5 Monitoring ..................................................................................................................................................26

2.2 Alternative 2 – Eliminate the Current Wolf Assistance Program ......................................................................26

2.3 Alternative 3 – Proposed Action Alternative – Expand the Current Wolf Assistance Program........................27

2.3.1 Formulating a strategy for wolf removal ....................................................................................................28

2.3.2 Description of Lethal Methods Available to WS........................................................................................28

2.3.3 Measures used by WS to Minimize Environmental Risk ...........................................................................30

2.3.4 Monitoring ..................................................................................................................................................37

2.4 Summary of Actions allowed by Alternative.....................................................................................................37

CHAPTER 3 - ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS ...........................................................40

3.1 Issues Driving the Analysis ...............................................................................................................................40

3.2 Issues Not Analyzed in Detail, with Rationale ..................................................................................................40

Additional issues not considered because they are outside the scope of this analysis.........................................43

3.3 Evaluation Methodology ...................................................................................................................................44

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES ..........................................................................................45

4.1 Alternative 1 – No Action..................................................................................................................................45

4.1.1 Impact on wolf population..........................................................................................................................45

4.1.2 Impacts on non-target animals and human safety.......................................................................................47

4.1.3 Social and Aesthetic Perspectives...............................................................................................................47

4.1.4 Effectiveness...............................................................................................................................................49

4.2 - Alternative 2 – Eliminate the Current Wolf Assistance Program....................................................................51

4.2.1 Impact on wolf population..........................................................................................................................52

4.2.2 Impacts on non-target animals and human safety.......................................................................................52

4.2.3 Social and Aesthetic Perspectives...............................................................................................................53

4.2.4 Effectiveness...............................................................................................................................................53

4.3 Alternative 3 – Proposed Action Alternative: Expand the Current Wolf Assistance Program..........................53

4.3.1 Impact on wolf population..........................................................................................................................54

4.3.2 Impacts on non-target animals and human safety.......................................................................................55

4.3.3 Social and Aesthetic Perspectives...............................................................................................................57
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington ii

4.3.4 Effectiveness...............................................................................................................................................58

4.4 Summary and Conclusions ................................................................................................................................59

CHAPTER 5 – Literature Cited...................................................................................................................................60

Appendix A: WDFW Letter .......................................................................................................................................67

Appendix B: 2011 MOU between WS and USFS ......................................................................................................69

Appendix C: Risk Assessment of Potential Direct Control Methods Used by APHIS WS........................................77

Appendix D: Summary of Public Comments and Responses on the December 2013 Pre-Decision Environmental 

Assessment Wildlife Services’ Gray Wolf Damage Management in Washington ......................................................91
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington iii

List of Acronyms and Abbreviations 

APHIS Animal and Plant Health Inspection Service (USDA agency)

AVMA American Veterinary Medical Association

BLM Bureau of Land Management (USDI agency)

CEQ President’s Council on Environmental Quality

CFR Code of Federal Regulations

EA Environmental Assessment

EIS Environmental Impact Statement

EJ Environmental Justice

EO Executive Order

ESA Endangered species Act

FR Federal Register

MIS Management Information System

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NRMDPS Northern Rocky Mountain Distinct Population Segment

RAG Radio Activated Guard

RCW Revised Code of Washington

T&E Threatened and Endangered 

USC United States Code

USDA United States Department of Agriculture

USDI United States Department of the Interior

USFS United States Forest Service (USDA agency)

USFWS United States Fish and Wildlife Service (USDI agency)

WAC Washington Administrative Code

WCMPW Wolf Conservation and Management Plan for Washington

WDFW Washington Department of Fish and Wildlife

WDM Wildlife Damage Management

WS Wildlife Services (USDA-APHIS program)
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington iv

EXECUTIVE SUMMARY

This environmental assessment (EA) evaluates a proposed action and alternatives to assist the 

Washington Department of Fish and Wildlife (WDFW), the United States Fish and Wildlife 

Service (USFWS), and Native American tribal governments with management of gray wolf 

(Canis lupus) conflicts throughout the state. The need for action is based on confirmed and 

repeated livestock depredation, expectations of increases in damages as the wolf population 

increases and expands in WA, and the potential for wolves to threaten human safety. The actions 

to protect livestock are immediately necessary where the gray wolf population is managed by 

WDFW. Assistance to WDFW may include technical assistance, harassment, lethal removal, 

live-trapping, collaring, translocation, and monitoring wolves. USFWS may authorize WDFW 

to conduct nonlethal wolf management (e.g., live-trapping, collaring, translocating wolves for 

study, or hazing) in portions of the state where wolves are protected under the Federal 

Endangered Species Act (ESA). When this occurs, WDFW may request the United States 

Department of Agriculture, Wildlife Services (USDA) to assist. USFWS may also directly 

authorize United States Department of Agriculture’s (USDA) Animal and Plant Health 

Inspection Service (APHIS) Wildlife Services (WS) to provide assistance with nonlethal wolf 

management actions where wolves are Federally-listed, in accordance with ESA guidelines. 

Legal status of wolves in Washington

The most pertinent and recent 

regulatory action was a 5 May 2011 

federal delisting of wolves from the 

federal Endangered Species Act 

(ESA) in eastern Washington, which 

will not be subject to judicial review 

(76 FR 25590; 5 May 2011, as 

mandated by Public Law 112–10). 

Under this rule, wolves were 

federally delisted in Washington east 

of Highway 97 from the British 

Columbia border south to Monse, 

Highway 17 from Monse south to 

Mesa, and Highway 395 from Mesa 

south to the Oregon border, but 

remained federally listed west of 

these highways (Figure 1) (74 FR 

15123; April 2, 2009). This boundary

falls within WDFW’s eastern wolf 

management zone.

Wolves in the eastern third of Washington within the Northern Rocky Mountain Distinct 

Population Segment (NRMDPS) boundary are federally delisted and now managed by WDFW

or, for those lands of Indian Nations which are identified as reservation lands, by the sovereign 

Figure 1. Map of the area designated by the U.S. Fish and 

Wildlife Service as the Northern Rocky Mountain distinct 

population segment of gray wolves.
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington v

tribal authority. Gray wolves are currently classified as endangered under Washington state law

throughout the state (Washington Administrative Code 232-12-297). Based on the expected reestablishment of wolves in Washington, WDFW developed a Final Recommended Wolf 

Conservation and Management Plan for Washington (WCMPW) on 28 July 2011

(http://www.wdfw.wa.gov/publications/00001/) to meet the requirements of the Washington

ESA. The WCMPW was adopted by the Washington Fish and Wildlife Commission on 3 

December 2011. It “. . . provides recovery goals for downlisting and delisting the species and 

prescribes strategies to achieve these goals, including management of conflicts with livestock 

and ungulates” (Wiles et al. 2011).

Gray wolves are expected to continue to increase in number in Washington. Outside of the 

NRMDPS boundary (western 2/3 of Washington, see Figure 1), wolves receive additional 

protections under the federal ESA where they are currently federally classified as endangered (74 

FR 15123; April 2, 2009). Where gray wolves are federally listed (those portions of Washington 

west of the NRMDPS line), the U.S. Fish and Wildlife Service is the responsible federal agency 

for regulatory compliance for any management decisions affecting wolves. On 7 June 2013, the 

U.S. Fish and Wildlife Service announced the release of their proposal to delist Gray wolves in 

Washington and elsewhere. The proposed rules were published in the Federal Register on 13 

June 2013. The Fish and Wildlife Service welcomed public comment for 90 days from the date 

of publication. If federal delisting occurs, gray wolves throughout the state would be managed 

according the WCMPW (Wiles et al. 2011, or as amended). Again, the exception to state 

management authority would be those lands managed under sovereign tribal authority.

Need for Action

The increasing presence of wolves in Washington initiated a need to mitigate and resolve 

conflicts when wolves cause harm to livestock. This EA discusses the direct and indirect effects 

of wolf depredation on livestock and public safety throughout Washington. The first likely wolf 

depredation on livestock was reported in Stevens County in September 2007. More recent wolf 

attacks on livestock were confirmed July through September 2012, in northeastern WA. 

Between August and September 2012, WDFW killed seven wolves from the Wedge Pack, 

including the alpha male and female, in order to reduce wolf predation on livestock and “reset 

the stage for sustainable wolf recovery in this region” (WDFW Director Phil Anderson, 

http://www.wdfw.wa.gov/news/sep2712b/). 

The number of documented livestock killed by wolves to date in Washington may represent a 

minimal number, with more livestock kills probably going unconfirmed. Lethal control of 

wolves may be necessary to resolve repeated wolf-livestock conflicts and would be performed to 

remove problem animals that jeopardize public tolerance for overall wolf recovery (Wiles et al.

2011). Wolf control may also be conducted to protect public safety. WDFW has requested WS 

to assist so WDFW personnel may focus their efforts on conservation and recovery instead of 

capture or removal. 
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington vi

Actions Analyzed

Wildlife Services (WS) proposes to assist WDFW, USFWS, and tribes with resolving gray wolf 

damage, as requested by WDFW under WAC 232-12-297 and the WCMPW or similar guidance. 

Actions would include assisting WDFW to reduce wolf conflicts to protect livestock, including

herding and guarding dogs, and human safety, as defined in WCMPW (Wiles et al. 2011). WS 

also proposes to assist WDFW with identifying wolf depredation events on livestock, providing a 

variety of non-lethal damage management assistance to livestock producers, research (e.g., livecapture, monitoring), and public education. At the request and direction of WDFW, WS may 

lethally remove de-listed wolves from packs identified as being involved in repeated livestock 

depredations.

At the request of USFWS, or WDFW acting as an authorized agent of USFWS, WS may take 

nonlethal actions (e.g., live-capture, monitoring) towards federally listed wolves. However 

under certain extenuating circumstances, lethal actions may be necessary in defense of human 

safety or for euthanasia in accordance with ESA guidelines1and Code of Federal Regulations 

(CFR)2. On tribal lands, WS may assist tribal governments with all forms of wolf management. 

All assistance provided by WS would comply with the WCMPW or similar guidance. 

Alternatives

A “No Action” alternative was evaluated for comparison to describe the environmental baseline. 

“No Action” refers to maintaining the current WS Wolf Assistance Program, which provides 

technical assistance and non-lethal direct control. If WS continued with the existing program 

(“No Action”), WDFW would implement the WCMPW to the best of its ability, including lethal 

control of wolves (Appendix A). The Eliminate the Current Wolf Assistance Program

alternative would prevent WS from conducting any wolf damage management, providing any 

technical assistance, or assisting in public education and outreach of wolf issues. The Proposed 

Action Alternative, Expand the Current Wolf Assistance Program, would allow WS to respond 

to requests from WDFW, USFWS, and tribes to assist with several aspects of the WCMPW, 

including lethally removing problem de-listed wolves at the request of WDFW or tribes as part 

of WDFW/USFWS overall conservation and recovery.

 

1 Under Section 11(a)(3), “Notwithstanding any other provision of this Act, no civil penalty shall be imposed if it 

can be shown by a preponderance of the evidence that the defendant committed an act based on a good faith belief 

that he was acting to protect himself or herself, a member of his or her family, or any other individual from bodily 

harm, from any endangered or threatened species.”

2

Fish and Wildlife Service regulations authorize certain federal and state employees and agents, when acting within 

the scope of their official duties, to take endangered and threatened species without a permit, "to aid a sick, injured, 

or orphaned specimen," to "dispose of a dead specimen," to "[s]alvage a dead specimen which may be useful for 

scientific study," or to "remove specimens which pose a demonstrable but nonimmediate threat to human safety." 50 

C.F.R. §§ 17.21(c)(2), 17.21(c)(3), and 17.31(a) (1993).
Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington vii

Environmental Consequences

The Proposed Action was examined to identify potential effects on the Washington wolf 

population, including the potential for wolf recovery and State ESA delisting. The EA examined

the effects on non-target animals, human safety, and on social and aesthetic perspectives 

including public acceptance, humaneness, and aesthetic enjoyment of wolves. The effectiveness 

of the alternatives in meeting the purpose and need and how well the alternatives alleviate 

livestock damages is also discussed. This EA found that there would continue to be a growing 

wolf population in Washington if the proposal is adopted, and it would likely have no or very 

few negative effects on other animals and humans.

WDFW indicated that if Wildlife Services does not adopt the Proposed Action Alternative,

necessary lethal actions would be implemented by the State of Washington, or its agents, as is 

demonstrated and discussed in the EA, WCMPW, and under the same strict guidelines as 

allowed by WDFW (Appendix A). WDFW further indicated that increased livestock losses 

would likely occur, more wolves might be removed, and WDFW’s overall wolf conservation 

efforts in Washington would be challenging without the assistance of the WS program (i.e., 

under the No Action or Eliminate the Current Program alternatives).

A No Action alternative (continue the current program of non-lethal and technical assistance 

only) was evaluated in detail. Social perspectives were similar between the No Action and 

Proposed Action Alternatives. Some members of the public might prefer the No Action 

alternative because WS would not kill any wolves, but WDFW, or its agents, would still remove 

problem wolves as allowed under the WCMPW (Wiles et al. 2011) and state law (RCW 

77.12.240) whether or not WS assisted. There could be negative environmental consequences if 

private citizens were allowed to lethally control wolves, rather than state or federal wildlife 

professionals because it is open to abuse when conducted by the public, thereby requiring law 

enforcement follow-up (Bangs et al. 2006). If WS was not allowed to provide any technical 

assistance or public education/outreach, wolf depredation may increase, which could result in a 

need to lethally remove more wolves. Requiring WDFW to devote its staff time towards lethal 

wolf control would detract from the time those personnel could devote to wolf conservation

(Appendix A, letter from WDFW). 

The Eliminate the Current Program alternative would prevent WS from providing any direct or 

technical assistance to WDFW, Washington citizens, and other public and private 

agencies/corporations in Washington. WDFW stated if WS did not assist with wolf depredation 

management, they would conduct the removals themselves. If WDFW professionals conducted 

wolf removal, there would be little difference in the environmental effects, except that wolf 

recovery may be hampered and possibly more wolves would need to be removed due to fewer 

efforts directed at proactive and preventative measures (Appendix A). But, there could be negative 

environmental consequences if private citizens were allowed to lethally control wolves, rather than 

state or federal wildlife professionals. If WS was not allowed to provide any technical assistance or 

public education/outreach, wolf depredation may increase, which could result in a need to lethally 

remove more wolves. WDFW indicated that it would be required to direct staff time towards 

responding to damages which would detract from wolf conservation and recovery (Appendix A). 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 1

CHAPTER 1. PURPOSE AND NEED FOR ACTION

Introduction

Historically, gray wolves (Canis lupus) were found throughout most or all of Washington before 

1800. They were essentially extirpated from the state by the 1930s 

(http://wdfw.wa.gov/conservation/gray_wolf/) through trapping, the use of toxicants, and 

shooting. The USFWS successfully reintroduced gray wolves into Idaho and Yellowstone 

National Park in 1995. From that, the wolf population in the northwestern United States 

increased substantially, leading to an expanded presence of wolves in Washington since 2002. 

Dispersal of wolves into Washington from British Columbia, Idaho, Montana, and Oregon has 

resulted in resident breeding population.

The gray wolf is listed as an endangered species throughout Washington under state law (WAC 

232-12-014) and under federal law [Endangered Species Act (ESA)] in the western two-thirds of 

Washington. Wolves in the eastern third of Washington were removed from federal listing in 

May 2011 and are now under state management (Figure 2). 

Managing human/wolf conflicts is an integral part of wolf management in Washington where 

emphasis is placed on goals and objectives that the Washington Department of Fish and Wildlife 

(WDFW) adopted in the Wolf Conservation and Management Plan for Washington (WCMPW) 

(Wiles et al. 2011). The WCMPW put forth strategies to minimize wolf conflicts by 

incorporating conflict avoidance, information, education, and limited lethal removals when 

repeated livestock depredations occur. The WCMPW defines “livestock” to mean: cattle, calves, 

pigs, horses, mules, sheep, lambs, llamas, goats, guarding animals, and herding dogs. The WCMPW 

also allows for responding to potential threats to human safety.

The WCMPW was initiated in 2011 to address the inevitable need to manage wolves in the state. 

The WCMPW would also serve the state’s legal obligations under the Washington ESA (WAC 

232-12-297).

Although livestock losses to wolves are minimal industry-wide, losses to individual operators 

can be significant (Fritts et al. 1992, Mack et al. 1992). Control of offending wolves, along with 

increased livestock management practices (e.g., carcass management, fencing, etc.), 

compensation for losses, and communication with the public have all contributed to wolf 

recovery where wolf-livestock conflicts exist (Fritts et al. 1992, Mack et al. 1992, Niemeyer et 

al. 1994, Bangs et al. 2006).

As of November 2013, there were ten confirmed packs in Washington: seven packs in the 

Eastern Washington management zone, three packs in the Northern Cascades management zone,

and none in the South Cascades & Northwest Coast management zone (Figure 2). There are also 

two suspected packs in the Eastern Washington management zone and two packs bordering 

Washington (one near Walla Walla and another in the north Cascade Mountains). Two solitary 

wolves (e.g., not associated with known packs) are confirmed to occur in northeastern

Washington.
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 2

WDFW requested that APHIS, Wildlife Services (WS) assist with managing gray wolf damage 

to livestock and potential risks to human safety, as defined in WCMPW. As wolves become 

established in the state, livestock damage is an anticipated result of actions by some wolves. The 

reason WS is requested to assist in these cases is because WS has special expertise in evaluating 

and confirming livestock depredation, technical expertise in non-lethal methods to minimize 

wolf damage, expertise in live-capturing for radio collaring /monitoring, and removing 

individual de-listed wolves responsible for depredation or that are deemed to be threats to 

livestock/public safety. WS also has personnel to provide wildlife damage management 

assistance, as well as aircraft and pilots/crews, and is readily suited to providing the requested 

assistance in an efficient and effective manner.

The proposed action would predominantly occur where gray wolves are not federally managed 

within Washington’s portion of the Northern Rocky Mountain Distinct Population Segment 

boundary3(NRMDPS) (Figure 1). Gray wolves throughout Washington are protected under 

state law as endangered (WAC 232-12-297), with three management zones having been 

established by WDFW and Washington Fish and Wildlife Commission (Figure 2). Therefore, 

gray wolves in NRMDPS area of the state (a portion of WDFW Eastern management zone) fall 

under the protection and management authority of WDFW. WS may also respond to requests

 

3 The NRMDPS in Washington includes that portion of Washington east of Highway 97 from the British Columbia 

border south to Monse, Highway 17 from Monse south to Mesa, and Highway 395 from Mesa south to the Oregon 

border (74 FR 15123; April 2, 2009).

Figure 2. Map of known wolf home ranges in Washington as of 15 November 2013.
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 3

from the USFWS and tribes regarding wolf damage management but does not anticipate taking 

lethal actions for federally listed wolves. 

Recent Legal Status Changes

Wolves were absent from Washington for more than 30 years when they gained endangered 

status in 1973 with their listing under the federal ESA. In 1987, USFWS completed the revised 

Northern Rocky Mountain Wolf Recovery Plan. Four years later Congress initiated an 

administrative process to reintroduce wolves into Yellowstone National Park (YNP) and central 

Idaho. In 1995 and 1996, 66 wolves were captured in Alberta and British Columbia, Canada. Of 

those, 35 were released in central Idaho and 31 were released into YNP. Wolves were protected 

as a “non-essential experimental population” under the federal ESA within a specified zone that 

included portions of Idaho, Wyoming, and Montana.

When the WCMPW was initiated in 2007, gray wolves in Washington were under the primary 

jurisdiction of the USFWS and were federally listed as endangered under the federal ESA of 

1973. On 4 May 2009, wolves in the NRMDPS (east of Hwy. 97/17/395) of Washington were 

removed from the protections of the federal ESA (Figure 1). However, on 5 August 2010, federal 

protections for wolves in the NRMDPS portion of Washington were reinstated, which meant that 

all wolves in Washington were federally-listed as endangered.

Subsequently, on 5 May 2011, the USFWS published a final rule implementing Public Law 112-

10, Section 1713, directing the Secretary of Interior to effectively delist wolves in the identified 

NRMDPS, including the portion of that boundary identified in Washington (Figure 1) (76 FR 

25590). That act of Congress changed the legal status of wolves in the eastern third of 

Washington (the NRMDPS portion of Washington) to no longer fall under federal protection. 

Thus the only protections in effect in this area are those established by state law under the 

Washington Endangered Species Act (WAC 232-12-297). On 7 June 2013, the U.S. Fish and 

Wildlife Service announced the release of their proposal to delist Gray wolves in Washington 

and elsewhere. The proposed rules were published in the Federal Register on 13 June 2013. The 

Fish and Wildlife Service welcomes public comment, which will be accepted for 90 days from 

the date of publication.

Wolf management is a relatively new issue in Washington. During the initial phases of recovery 

of the gray wolf under the Washington State ESA as outlined in the WCMPW, federally delisted 

wolves involved in repeated depredation may be killed by WDFW, WDFW authorized agents, or 

WS after confirmation by WDFW. The requester will document unsuccessful attempts to solve 

the situation through non-lethal means. WS may assist WDFW with determining the cause of 

death in wolf damage complaints; however WDFW will make the final determination. WS may 

also assist USFWS with the management of federally listed wolves in accordance with USFWS 

guidance and/or the WMCPW. WS may also assist tribes with management of wolves on 

sovereign tribal lands under the WCMPW or similar guidance. 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 4

1.1 Purpose

Purpose of the Proposal

The purpose of the proposed action is to reduce livestock depredation by gray wolves in 

Washington. Additionally, the purpose of this proposal is to be available to assist WDFW, 

USFWS, sovereign tribal governments, or the public in the unlikely event that wolves threatened 

public safety [50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) (1993)]. WS determined it would only 

conduct actions on behalf of WDFW, USFWS, or tribal governments in accordance with 

WDFW’s conservation and management objectives and goals as defined in detail in the

WCMPW or similar guidance.

1.2 Need for Action

Direct predation on livestock

The WCMPW calls for recovery of wolves in Washington, which provides a reasonable 

expectation that wolves in Washington will increase in number in the foreseeable future. Along 

with the expectation of increased wolf numbers is the expectation that depredation on livestock 

will also increase. The increasing presence of wolves in Washington initiated a need to mitigate 

and resolve conflicts when wolves cause harm to livestock. Lethal control of de-listed wolves 

may be necessary to resolve repeated wolf-livestock conflicts and would be performed to remove 

problem animals that jeopardize public tolerance for overall wolf recovery (Wiles et al. 2011).

This EA discusses the direct and indirect effects of wolf depredation on livestock and public 

safety. 

The first likely wolf depredation on livestock was reported in Stevens County in September 

2007. More recent wolf attacks on livestock were confirmed July through September 2012, in 

northeastern WA. In August and September 2012, WDFW killed seven wolves from the Wedge 

Pack, including the alpha male and female, in response to escalating wolf attacks on livestock 

and “reset the stage for sustainable wolf recovery in this region” (WDFW Director Phil 

Anderson, http://www.wdfw.wa.gov/news/sep2712b/). 

The number of documented livestock killed by wolves to date in Washington may represent a 

minimal number, with more livestock kills probably going unconfirmed. Lethal control of 

wolves may be necessary to resolve repeated wolf-livestock conflicts and would be performed to 

remove problem animals that jeopardize public tolerance for overall wolf recovery (Wiles et al.

2011). Wolf control may also be conducted to protect public safety. WDFW requested WS to 

assist so WDFW personnel could focus their efforts on conservation and recovery instead of 

capture or removal.

Confirmed losses underestimate probable losses

It is important to recognize that the numbers of livestock that have been confirmed to be killed 

by wolves to date in Washington may represent only the minimum numbers of livestock actually 

killed and injured by wolves, and that more livestock were probably killed but not confirmed as 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 5

wolf predation (Bjorge and Gunson 1985, Oakleaf et al. 2003). For example, in the Order 

Staying Enforcement of Rule Pending Judicial Review Conditioned on Providing Security, one 

Oregon cattle producer declared that he suffered the loss of two pregnant cows, one bull, and two 

yearlings to wolves during part of a one year, but only two of his animals were confirmed as 

wolf kills (Cascadia Wildlands, et al. v. Dept. of Fish and Wildlife, et al., No. 149672 (Or. Ct. 

App. Nov. 15, 2011) order staying enforcement of rule pending judicial review). For the 

confirmed wolf kills, he received a compensation payment in the amount of $8004but he 

incurred additional losses of $6,600. Thus, this producer was compensated for about 11 % of his 

direct losses which totaled $7,400.

Oakleaf et al. (2003) conducted a study on wolf-caused predation losses to cattle on U.S. Forest 

Service (USFS) summer grazing allotments near Salmon, Idaho, and concluded that for every 

calf found and confirmed to have been killed by wolves, there were as many as 8 other calves 

killed by wolves but not found by the producer, depending upon ruggedness or presence of 

heavily timbered areas. In areas less rugged or timbered, the ratio could be lower. Bjorge and 

Gunson (1985) likewise recovered only 1 out of every 6.7 missing cattle during their study and 

suggested that wolf-caused mortalities were difficult to detect.

Confirmed incidents of wolf predation on livestock may involve only one or several livestock 

killed or wounded per incident, but there have also been situations where larger numbers of 

livestock have been killed in a single incident, particularly in the case of wolf attacks on sheep. 

Muhly and Musiani (2009) reviewed data on wolf predation on livestock in Idaho, Montana and 

Wyoming from 1987-2002 and found that while most wolf attacks on cattle involved the death of 

only 1 animal per incident, wolf attacks on sheep typically involved killing about 14 animals per 

incident, with up to 98 sheep killed in a single attack. In Oregon, one producer suffered 22 lamb 

losses to wolves in one day. The same producer also incurred additional lamb losses and the loss 

of a goat in the days and months that followed, all by the same wolves (ODFW 2012).

WDFW requires a standard of conclusive evidence before wolf-caused livestock depredations 

are confirmed (Wiles et al. 2011). In some cases, wolves may have been responsible for the 

death of a rancher’s livestock, but there was insufficient evidence remaining to confirm wolf 

predation. In other cases, those portions of the livestock carcass that might have contained the 

evidence of predation may already have been consumed, carried off, or decomposed. Some of 

these incidents might be classified as “probable” predation, depending on other evidence that 

might still remain. But in many cases, there may be little or no conclusive evidence of predation, 

other than the fact that wolves are known to be in the area and some livestock have seemingly 

disappeared.

As wolf populations increase and expand their range, local decision makers must choose 

management strategies that balance competing needs for wolf protection and the reduction of 

wolf-caused damage (Mech 2001). Wolves prey on domestic animals in all parts of the world 

where the two coexist (Mech and Boitani 2003, ODFW 2010). Data from the NRMDPS suggest 

that individual wolves do not automatically prey on livestock, but members of wolf packs 

 

4 Compensation was provided by a Defenders of Wildlife fund which is no longer in effect.
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 6

encountering livestock on a regular basis are likely to depredate sporadically (Bangs and Shivik 

2001).

The relative risk of predation on livestock posed by individual wolves was analyzed by WS for 

Idaho (USDA 2011a). The authors measured the likelihood for depredation to occur from 

wolves, black bears, cougars, and coyotes and showed that individual wolves were more likely to 

depredate on sheep and cattle than individual coyotes, bears, and cougars.

Where and how livestock are managed and where and how wolves are managed will influence 

depredation rates. In Alberta, Canada, cattle on heavily forested but less intensively managed 

grazing allotments suffered three times as many depredation incidents as more intensively 

managed lease areas having less forest cover (ODFW 2010). In North America and Europe, 

untended livestock occupying remote pastures suffered the greatest losses from wolves. 

Newborn livestock held in remote pastures are more vulnerable to wolf predation. 

Indirect depredation effects on livestock

Although direct losses of livestock due to predation are often conspicuous and economically 

significant to affected producers, they likely underestimate the total impact on producers because 

they do not consider indirect effects as a result of livestock being exposed to the threat of 

predation (Howery and DeLiberto 2004, Lehmkuhler et al. 2007). Shelton (2004) suggested that 

the value of livestock killed by predators is the “tip of the iceberg” in assessing the actual costs 

that predators impose on livestock and producers including time and effort spent looking for 

missing livestock, and increased costs associated with efforts to mitigate predation which may 

include night confinement, improved fencing, additional livestock guarding animals, early 

weaning, choice of grazing area, and/or increased feeding costs related to loss of grazing 

acreage.

Using an example of a producer in Oregon who incurred $7,400 in direct cattle losses (Cascadia 

Wildlands, et al. v. Dept. of Fish and Wildlife, et al., No. 149672 (Or. Ct. App. Nov. 15, 2011)

order staying enforcement of rule pending judicial review), increased labor and other costs

brought his economic impact from wolves during a portion of one year to over $18,000. Indirect 

costs are not included in compensation payments, therefore, when considering his compensation 

payment of $800 for a portion of his direct losses, this producer was compensated for only about 

four percent of his total (direct and indirect) losses. In another example (Cascadia Wildlands, et 

al. v. Dept. of Fish and Wildlife, et al., No. 149672 (Or. Ct. App. Nov. 15, 2011) order staying 

enforcement of rule pending judicial review), a cattle producer which estimated $4,900 in cattle 

losses to wolf depredation, (not including lost profits), also incurred additional management 

costs of $19,000. These examples illustrate the severity of indirect economic consequences that 

wolf depredation and threats can have on individual livestock operations.

Indirect impacts to livestock arise from the stress and disruption associated with the presence of 

wolves or wolves pursuing herd mates. Effects on livestock may include reduced weaning 

weights, increased cattle aggressiveness, and delayed rebreeding, as well as increased production 

costs associated with an increased level of vigilance, alteration of pasture rotation and turnout 

timing, and handling costs. Harassment by predators may directly cause livestock to lose weight 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 7

due to increased energy expenditure associated with running and loss of sleep, but may also 

indirectly reduce the ability of ruminants to convert plant nutrients into weight gain due to 

decreased rumination time (Howery and DeLiberto 2004). Cattle and sheep exposed to 

harassment by predators become very skittish and spend much of their time remaining vigilant 

for predators (Kluever et al. 2008). They do not disperse and feed normally, and therefore may 

not take in the quantity and quality of feed they would have if unstressed, resulting in reduced 

weight gains at the end of the grazing season (Muhly et al. 2010). In addition, cattle are 

sometimes stampeded through fences and injured when wolves chase them (Lehmkuhler et al. 

2007). Lehmkuhler et al. (2007) also suggested that wolves could stress cattle by chasing them 

repeatedly which can also cause cattle to abort calves, calve early, or give birth to a weak calf.

Wolf predation on dogs

As wolves expand their range in Washington, dog owners will need to be aware of the potential 

risks to their animals. Areas or situations where wolves and domestic dogs encounter each other 

can result in dog mortality. In some instances, wolves may alter their regular movements or 

activities to seek out and confront domestic dogs (ODFW 2010). In Wisconsin, wolf depredation 

on hounds used for black bear hunting resulted in more compensation payments than for 

livestock (Treves et al. 2002). In Minnesota, 25 dogs were reported killed by wolves in 1998 

alone (Bangs and Shivik 2001, Mech and Boitani 2003). The killing of guard dogs by wolves 

has been documented in the Rocky Mountain Recovery Area. However, guard dogs appear to be 

more effective and less at risk when an adequate numbers of dogs per herd are present coupled 

with the presence of trained herders. Livestock producers using working dogs in conjunction 

with trained herders face added costs to protect their livestock from potential wolf depredation. 

Working dogs and trained herders may be more effective for protecting sheep flocks than cattle

(ODFW 2010).

In Washington, some wolves are likely to occupy areas near human habitation or areas used for 

recreation which could put pets or working dogs at risk. Dogs working cattle or sheep could be 

vulnerable in these situations. Public education will be important in preventing wolf/domestic 

dog interactions. Livestock guarding and herding dogs are often highly valued animals, both 

from a monetary standpoint and in terms of the human-social bond. Individual livestock 

guarding dogs may be worth more than $1,000 each.

To date, no working dogs have been confirmed as lost due to a wolf attack in Washington;

however, one dog guarding sheep in the vicinity of the Teanaway pack was injured, requiring 

veterinary care (Dave Ware, WDFW, pers. comm.). As wolf numbers increase, potential 

conflicts could be expected.

1.3 Scope of Analysis – Location and Actions Analyzed 

Location

Currently, federally delisted wolves occur within the Washington portion of the NRMDPS which 

is defined as the area east of Highway 97 from the British Columbia border south to Monse, 

Highway 17 from Monse south to Mesa, and Highway 395 from Mesa south to the Oregon 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 8

border. Nonlethal wolf damage management may occur as requested by WDFW, USFWS, or 

sovereign tribal governments wherever potential or confirmed repeated depredations arise. 

Wolf depredation management actions to assist WDFW, USFWS, or sovereign tribal 

governments are currently expected to occur in very limited and isolated geographic locations 

because wolves are not yet numerous or widely distributed in Washington, and thus resultant 

conflicts have been relatively few, compared with conflicts in other states or by other predators

in Washington. Even when wolf numbers increase, lethal removals would be limited to those 

constraints presented by WCMPW, USFWS regulations, or tribal authority.

The likely locations included in the analysis would include any land at or near the depredation 

incident, and is likely to occur on private, state, tribal, or federal land including USFS and

Bureau of Land Management (BLM) lands where livestock are grazed.

If wolves are removed from the federal ESA outside the NRMDPS, they would be managed by 

WDFW under the WCMPW. Thus any actions allowed by the WCMPW, as amended, would 

apply to wolves throughout the state. While no packs have become established in the Southern

Cascades and Northwest Coast, expansion into the western third of Washington is anticipated.

Site Specificity

This EA analyzes the potential impacts of WS’ wolf damage management on all lands in 

Washington where conflicts with livestock and human safety may occur. Specific locations or 

times where such damage will occur cannot be predicted due to the mobility and unpredictability

of wolves, and the distribution of livestock across the Washington landscape. Therefore, this EA 

anticipates all substantive environmental issues that are likely to exist where wolf damage 

management may occur. The WS Decision Model (Slate et al. 1992) is the site-specific 

mechanism for determining the most appropriate actions to take within the scope of actions 

allowed under any NEPA decision. Any substantive new issue or change in circumstance that 

might arise with wolf damage management which has not been considered in this EA may 

require additional NEPA compliance. Therefore this EA meets the intent of NEPA with regard 

to site-specific analysis.

Actions Analyzed

This EA evaluates WS proposed actions to assist WDFW, USFWS, or tribal governments in 

providing advice, information, and direct assistance to livestock producers with non-lethal 

methods that can be used to aid in wolf conflict prevention, and to lethally remove federally 

delisted wolves at the request of WDFW or tribes if wolves have been confirmed as having 

caused repeated livestock depredation or for USFWS under the guidance of the ESA. WS also 

proposes to assist WDFW, USFWS, and sovereign tribal governments by using its expertise to 

determine whether or not wolves were responsible for depredation. Other than on sovereign 

tribal lands, only WDFW or USFWS will make the final confirmation of repeated livestock 

depredation. Lethal take of federally delisted wolves under WDFW control is allowed by 

livestock owners, (including family members and authorized employees) on private land they 

own or lease at all listed statuses, with an issued permit, after documented depredation (injury or 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 9

killing) in the area and efforts to resolve the problem have been deemed ineffective (WDFW 

2011). On 26 April 2013, WDFW enacted an emergency rule: 

WAC 232-36-05100B Killing wildlife causing private property damage

Notwithstanding the provisions of WAC 232-36-051:

1) An owner of domestic animals, including livestock, the owner's immediate 

family member, the agent of an owner, or the owner's documented employee may 

kill one gray wolf (Canis lupus) without a permit issued by the director, regardless 

of its state classification, if the wolf is attacking their domestic animals.

 (a) This section applies to the area of the state where the gray wolf is not listed 

as endangered or threatened under the federal endangered species act.

 (b) Any wolf killed under this authority must be reported to the department 

within twenty-four hours.

 (c) The wolf carcass must be surrendered to the department.

 (d) The owner of the domestic animal must grant or assist the department in 

gaining access to the property where the wolf was killed for the purposes of data 

collection or incident investigation.

(2) If the department finds that a private citizen killed a gray wolf that was not 

attacking a domestic animal, or that the killing was not consistent with this rule, 

then that person may be prosecuted for unlawful taking of endangered wildlife 

under RCW 77.15.120.

(3) In addition to the provisions of (1), the director may authorize additional 

removals under RCW 77.12.240.

WS may act as an authorized agent on a depredation permit, to remove federally delisted gray 

wolves under WDFW permit conditions for livestock producers or permittees. The specific nonlethal and lethal measures to reduce wolf conflicts are discussed in detail in the Sections 2.1 and 

2.3. At the request of USFWS or WDFW acting as an authorized agent of USFWS, WS may 

take nonlethal actions towards federally listed wolves. WS would not take any actions towards 

federally listed wolves outside the guidance of the ESA. On tribal lands, WS may assist tribal 

governments with all forms of wolf management. All assistance provided by WS would comply 

with the WCMPW or similar guidance. 

A critical factor guiding this analysis is that WS wolf damage management activities would be

conducted only at the request of WDFW, USFWS, affected property owners (for nonlethal 

assistance), and tribal governments. WS has no decision making authority for where or when to 

remove problem wolves when acting at the request of USFWS, WDFW or WDFW authorized 

depredation permit holders. WS can only decide if it will accept WDFW, USFWS, or tribal

requests to remove problem wolves. Wolf damage management strategies are established in the

WCMPW to ensure conservation and management goals will be met, therefore, any action 

selected must fall within those measures allowed under WCMPW, as it is updated. As discussed 

under the Proposed Action Alternative, on tribal lands WS would conform to similar 

implementation guidelines for the management of wolf depredation including limitations on the 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 10

lethal removal of wolves. Where wolves are federally listed, WS would not take any lethal

actions outside the guidance of the ESA.

WDFW will remove problem wolves in the absence of assistance from WS (Appendix A).

Requests for assistance by sovereign tribal governments in the foreseeable future are possible but 

not likely. Therefore the actions analyzed in this EA are weighed against the environmental 

baseline or the environmental status quo of wolf depredation management by the responsible 

wildlife management agencies.

1.4 WDFW Wolf Management Goals

Under WDFW request, WS actions would abide by the WCMPW. Any work performed by WS 

on tribal lands or where wolves are federally listed, would conform to tribal/federal regulations 

or similar implementation guidelines outlined in the WCMPW.

Managing livestock conflicts: WDFW’s objectives for addressing wolf damage to livestock, as 

stated in the WCMPW, are to develop and implement a phased approach based on population 

objectives for wolves that ensures conservation of the species while minimizing conflicts with 

livestock.

Managing wolf populations: WDFW’s wolf population objectives are separated into three 

regions: Eastern Washington, Northern Cascades, and Southern Cascades and Northwest Coast 

(Figure 2). The Northern Cascades zone and Southern Cascades and Northwest Coast zone fall 

outside the NRMDPS and are currently under federal ESA rules. 

The goals of the WCMPW are to:

 Restore the wolf population in Washington to a self-sustaining size and geographic 

distribution that will result in wolves having a high probability of persisting in the state 

through the foreseeable future (>50-100 years).

 Manage wolf-livestock conflicts in a way that minimizes livestock losses, while at the 

same time not negatively impacting the recovery or long-term perpetuation of a 

sustainable wolf population.

 Maintain healthy and robust ungulate populations in the state that provide abundant prey 

for wolves and other predators as well as ample harvest opportunities for hunters.

 Develop public understanding of the conservation and management needs of wolves in 

Washington, thereby promoting the public’s coexistence with the species.

Meeting the delisting criteria outlined in WCMPW will necessitate tolerance for wolves on 

public and private lands. Therefore, to achieve conservation of wolves in Washington as 

required by the state ESA, the WCMPW outlines a range of options for livestock producers to 

deal with problem wolves. While the WCMPW describes measures that WDFW will take to 

conserve and manage the species, it provides for non-lethal and lethal management strategies that 

could be taken to protect livestock from wolf depredation and address human safety concerns.

These measures are outlined in Section 2.3 and detailed in the WCMPW.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 11

1.5 Period for which this EA Remains Valid 

This EA may remain valid until WS, in consultation with WDFW, USFWS, and affected

sovereign tribal governments, determines that the need for action, issues driving this EA, 

environmental conditions, or wolf management plans have changed substantially. Substantive 

changes may trigger the need to review and amend the analysis in this EA, further involve the 

public, and provide the decision-maker with additional information necessary to make an 

informed decision about WS’ role in wolf damage management in Washington. The need for 

action to protect livestock from wolf predation and protect public safety, as described in Section

1.2, would be expected to increase over time as Washington’s wolf populations grow and 

expand. The WCMPW uses adaptive management to incorporate new information into 

WDFW’s management schemes which may affect when and where WS would take actions. WS 

would follow this adaptive management scheme by adjusting to the changes. Wolf management 

as conducted by WDFW is expected to continue into the foreseeable future and result in an 

eventual state delisting.

1.6 Decision to be Made

Based on agency relationships, Memoranda of Understanding (MOUs) and legislative direction, 

WS is the lead agency for this EA, and therefore responsible for the scope, content, and decisions

made. WDFW and USFWS were consulted during the development of the EA, and the USFS, 

BLM, Washington Department of Agriculture (WDA), and tribes had opportunity for input 

during preparation of the EA.

Based on the scope of this EA, the decisions to be made are:

 Should the Washington WS program respond to WDFW requests for assistance with the 

WCMPW as well as assisting USFWS and sovereign tribal governments?

 Might there be other reasonable alternatives that could be selected?

 What are the likely environmental effects of the alternatives, and could the proposed 

action have significant effects on the quality of the human environment and therefore 

require an EIS?

1.7 Summary of Public Involvement Efforts 

Scoping, agency, and public input in the NEPA process for this EA were conducted consistent 

with WS NEPA procedures. Issues related to the proposed action were identified from: 

cooperating agency input from WDFW including the WCMPW and Final EIS for Wolf 

Conservation and Management Plan for Washington, prior WS experience with wolf 

management issues in other states (USDA 2011a, USDA 2008, and USDA 2006), agency 

knowledge of wolf damage management issues in Washington, and interagency and tribal

reviews of the draft EA.

This EA was made available to the public by posting the notice of its availability on the WS

website at http://www.aphis.usda.gov/wildlife_damage/nepa.shtml, by issuing a legal notice in 

the Olympian on December 17, 2013, and by posting the pre-decisional EA on
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 12

http://www.regulations.gov/#!docketDetail;D=APHIS-2013-0107. All substantive comments 

received according to the instructions provided in the notices will be considered in the finalized

EA. A summary of public comments and response will be contained in Appendix D after they 

are received.

Wildlife Services received 44 public comment letters (some of which included attachments 

providing additional comment) and considered all comments. A summary of the public 

comments and responses is contained in Appendix D. Notices of the availability of the final EA 

and the Finding of No Significant Impact will be placed in the same newspaper (the Olympian) 

that announced the availability of the pre-decision EA, at 

http://www.regulations.gov/#!docketDetail;D=APHIS-2013-0107, and at 

http://www.aphis.usda.gov/wildlife_damage/nepa.shtml.

1.8 Relationship of this EA to other Environmental Documents 

Final Rule to Delist NRMDPS

On 5 May 2011, USFWS published a final rule to remove protections of the ESA from most of 

the concurrently designated gray wolf NRMDPS (74 FR 15123). The population of wolves in 

the eastern one third of Washington was included in this delisting, as they were part of the 

NRMDPS. Background information on the NRM gray wolf population was contained in the 

USFWS 2 April 2009, Final Rule (74 FR 15123) http://www.regulations.gov 5

2011 Wolf Conservation and Management Plan for Washington.

The WCMPW provides relevant discussions which are summarized herein. The relationship of 

the WCMPW to this EA is that it provides the framework and basis for describing the existing 

environment and no action alternative, and it sets parameters and limitations on the Proposed 

Action Alternative. The No Action and Eliminate the Current Wolf Assistance Program

alternatives are not consistent with WDFW management goals and objectives, as specified in the 

WCMPW.

Final Environmental Impact Statement for the Wolf Conservation and Management Plan for 

Washington.

WDFW issued a Final EIS on wolf conservation and management for Washington on 28 July 

2011. This document served as a backbone for the WCMPW and relevant information available 

in the EIS has been incorporated by reference into this EA.

 

5

Lawsuits challenging the USFWS April 2, 2009, final rule were filed in U.S. District Court for the District of Montana and U.S. District Court 

for the District of Wyoming. On August 5, 2010, the U.S. District Court for the District of Montana vacated and set aside our 2009 delisting rule 

(Defenders of Wildlife et al. v. Salazar et al., (729 F. Supp. 2d1207 (D. Mont.). On April 15, 2011, President Obama signed Public Law 112–

10—The Department of Defense and Full-Year Continuing Appropriations Act, 2011. Section 1713 of Public Law 112–10 which required the 

Secretary of the Interior to reissue the final rule published on April 2, 2009 (74 FR 15123 et seq.), and that the reissuance could not be subject to 

judicial review. 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 13

Final EIS on the Reintroduction of Gray Wolves to Yellowstone National Park and Central Idaho

The USFWS (1994) issued a Final EIS and Decision regarding the potential impacts of 

reintroducing wolves to YNP and central Idaho. Part of the analysis in the EIS assessed potential 

impacts of a fully-recovered wolf population on livestock. This EIS also assessed the anticipated 

impact of wolf removals for protection of livestock. Relevant analysis from USFWS (1994) is 

incorporated by reference in this EA.

1.9 Authority and Compliance 

WS cooperates with land and wildlife management agencies to resolve wildlife damage problems 

in compliance with applicable federal, state and local laws.

1.9.1 Authority of Federal and State Agencies in Wolf Damage Management 

APHIS-Wildlife Services

The WS program is authorized to carry out wildlife damage management programs necessary to 

protect the Nation’s agricultural and other resources. The primary statutory authorities are the 

Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C. 426-426b) as amended, and the Act of December 

22, 1987 (101 Stat. 1329-331, 7 U.S.C. 426c). WS recognizes that wildlife is an important 

public resource greatly valued by the American people. By its very nature, however, wildlife is a 

highly dynamic and mobile resource that can damage agricultural resources, pose risks to human 

safety, and affect other natural resources. The WS program provides federal leadership in 

helping to solve problems that occur when human activity and wildlife are in conflict with one 

another.

United States Bureau of Land Management (BLM)

The BLM manages lands under its jurisdiction for multiple uses including livestock grazing, 

recreation, wildlife habitat, and other uses while recognizing the state's authority to manage 

resident wildlife. The BLM recognizes the importance of managing wildlife damage on lands 

and resources under its jurisdiction, as integrated with its multiple use responsibilities. Similar to 

the USFS, BLM and WS have entered into a MOU which identifies the roles and responsibilities 

of each agency in animal damage management operations, coordination, and NEPA compliance. 

WS currently does not conduct work on BLM lands, but may so at their request or may 

coordinate with them when requested by a grazing leasee.

United States Fish and Wildlife Service (USFWS)

The USFWS is a federal agency within the U.S. Department of the Interior authorized to manage 

fish, wildlife, and habitats. USFWS mission reads, “working with others to conserve, protect, 

and enhance fish, wildlife, plants and their habitats for the continuing benefit of the American 

people.” As the principal federal agency responsible for administering the ESA, the USFWS 

takes the lead in recovering and conserving imperiled species by fostering partnerships, 

employing scientific excellence, and developing a workforce of conservation leaders.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 14

United States Forest Service (USFS)

The USFS has the responsibility to manage National Forests for multiple uses including 

livestock grazing, timber production, recreation, and wildlife habitat, while recognizing the 

state's authority to manage resident wildlife. The USFS recognizes the importance of managing 

wildlife damage on lands and resources under their jurisdiction, as integrated with their multiple 

use responsibilities. The USFS and WS have a MOU agreeing that “APHIS-WS is designated as 

the lead agency concerning wildlife damage management (WDM) and wildlife disease activities, 

and that in evaluating the need for, and in conducting WDM programs, multiple-use values must 

be considered”. The MOU directs the USFS to coordinate with WS in the development and 

annual review of wildlife damage management plans governing WS’ activities on National 

Forest System lands and to cooperate in WS’ NEPA processes. WS currently does not work on 

USFS lands, but could be requested to do so in the future. Work done on USFS lands would be 

conducted in coordination with the Regional Forester and under annual WDM work plans. In 

this way, the USFS ensures that proposed wildlife damage management activities are consistent 

with forest land uses as allowed under its Land and Resource Management Plans and Forest 

Plans.

Washington Department of Fish and Wildlife

WDFW has the authority to manage all wildlife in Washington. RCW 77.04.012 mandates that 

“the commission, director, and the department [WDFW] shall preserve, protect, perpetuate, and 

manage the wildlife and food fish, game fish, and shellfish in state waters and offshore waters”. 

In part, this policy states that the WDFW shall conserve the wildlife and food fish, game fish, 

and shellfish resources in a manner that does not impair the resource and may authorize the 

taking of wildlife, food fish, game fish, and shellfish only at times or places, or in manners or 

quantities, as in the judgment of the commission does not impair the supply of these resources.

1.9.2 Compliance with Federal and State Laws, Policies and Executive Orders

Several federal and state laws regulate wildlife damage management. WS complies with 

relevant federal and state laws, and consults and cooperates with other agencies as appropriate.

Bureau of Land Management

Under the Act of 1931, as amended, (7 U.S.C. 426-426c), BLM and WS, along with the states, 

cooperate to manage animal damage on BLM lands. Similar to the USFS, BLM and WS have 

entered into a MOU which identifies the roles and responsibilities of each agency in animal 

damage management operations and coordination, and NEPA compliance. The BLM is 

responsible for the management of land and resources under its jurisdiction and for conducting 

non-predator control operations on its’ lands, including NEPA compliance on these activities. 

The MOU directs BLM to coordinate with WS in the development and annual review of animal 

damage management work plans governing WS’ activities on BLM lands and to cooperate in 

WS NEPA processes.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 15

Executive Order (EO) 12898 - Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

Environmental Justice (EJ) promotes the fair treatment of people of all races, income and culture 

with respect to the development, implementation and enforcement of environmental laws, 

regulations and policies. Fair treatment implies that no person or group of people should endure 

a disproportionate share of the negative environmental impacts resulting either directly or 

indirectly from the activities conducted to execute this country's domestic and foreign policies or 

programs. All WS activities are evaluated for their impact on the human environment and 

compliance with EO 12898 to ensure EJ. WS personnel use wildlife damage management 

methods as selectively and environmentally conscientiously as possible. No pesticides are 

proposed for use. It is not anticipated that the proposed action would result in any adverse or 

disproportionate environmental impacts to minority or low-income persons or populations.

EO 13045 - Protection of Children from Environmental Health and Safety Risks

Children may suffer disproportionately from environmental health and safety risks for many 

reasons. Wolf damage management as proposed in this EA would only involve legally available 

and approved damage management methods in isolated or remote situations and otherwise under 

circumstances where it is highly unlikely that children would have an opportunity to be exposed 

and potentially be adversely affected. Therefore, implementation of the Proposed Action

Alternative would not increase environmental health or safety risks to children.

Federal Endangered Species Act

It is federal policy, under the ESA, that all federal agencies shall seek to conserve endangered 

and threatened species and shall utilize their authorities in furtherance of the purposes of the 

ESA [Sec. 7(a)(2)]. Section 7 consultations with the USFWS are conducted to use the expertise 

of the USFWS to ensure that "any action authorized, funded, or carried out by such an agency is 

not likely to jeopardize the continued existence of any endangered or threatened species. WS

conducts Section 7 Consultations with the USFWS when proposed actions may affect federally 

listed species.

Under Section 11(a)(3), “Notwithstanding any other provision of this Act, no civil penalty shall 

be imposed if it can be shown by a preponderance of the evidence that the defendant committed 

an act based on a good faith belief that he was acting to protect himself or herself, a member of 

his or her family, or any other individual from bodily harm, from any endangered or threatened 

species.”

Fish and Wildlife Act of 1956 (section 742j-1) Airborne Hunting

This Act, approved in 1971, was added to the Fish and Wildlife Act of 1956 and is commonly 

referred to as the Airborne Hunting Act or Shooting from Aircraft Act. The Act allows shooting 

animals from aircraft for certain reasons including protection of wildlife, livestock, and human 

life as authorized by a federal or state issued license or permit. USFWS regulates the Airborne 

Hunting Act but has given implementation to the states. WDFW or its agent is authorized to 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 16

conduct aerial shooting as described under this proposal according to WAC 232-12-057 (Hunting 

with the aid of aircraft, boats, or other vehicles).

National Environmental Policy Act

NEPA requires that federal actions be evaluated for environmental impacts, that these impacts be 

considered by the decision maker(s) prior to implementation, and that the public be informed. 

This EA has been prepared in compliance with NEPA (42 USC Section 4231, et seq.,); the 

President’s Council on Environmental Quality (CEQ) Regulations, (40 CFR Section 1500 –

1508), and USDA APHIS NEPA Implementing Regulations (7 CFR Part 372).

One purpose of any EA is to “. . . briefly provide sufficient evidence and analysis for 

determining whether to prepare an environmental impact statement or a finding of no significant 

impact” (40 CFR 1508.9). If the environmental impacts are found to be significant, the NEPA 

process would likely be continued and an EIS would be prepared. If the impacts of the proposal 

are not found to be significant on the human environment, a Finding of No Significant Impact 

and decision to implement a selected alternative may be issued.

National Historic Preservation Act (NHPA) of 1966, as amended

The NHPA requires federal agencies to: 1) evaluate the effects of any federal undertaking on 

cultural resources, 2) consult with the State Historic Preservation Office regarding the value and 

management of specific cultural, archaeological and historic resources, and 3) consult with 

appropriate American Indian tribes to determine whether they have concerns for traditional 

cultural resources in areas of these federal undertakings. We have determined that the proposed 

action is not a federal “undertaking” as defined by NHPA and would not affect cultural 

resources.

Tribal Authorities

When working with tribes, the Departments recognize that Indian lands, whether held in trust by 

the United States for the use and benefit of Indians or owned exclusively by an Indian tribe, are 

not subject to the controls or restrictions set forth in federal public land laws. Indian lands are not 

federal public lands or part of the public domain, but are rather retained by tribes or set aside for 

tribal use pursuant to treaties, statutes, court orders, executive orders, judicial decisions, or 

agreements. Accordingly, Indian tribes manage Indian lands in accordance with tribal goals and 

objectives, within the framework of applicable laws.

U.S. Fish and Wildlife Service

Currently wolves in the NRM are managed by the USFWS with cooperation from the other 

agencies and tribes. While all federal agencies have the responsibility to “utilize their authorities 

in furtherance of the purposes of the ESA . . . pursuant to section 4” of the ESA, the USFWS has 

primary authority for endangered species recovery. Currently, the USFWS has legal 

responsibilities for wolf recovery in the western 2/3rd of WA; however, the USFWS can, through 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 17

cooperative agreements and other documents permit the states and tribes to lead implementation 

of wolf restoration efforts, as long as those programs are within the authorities of the ESA.

Fish and Wildlife Service regulations authorize certain federal and state employees and agents

(which could include WS), when acting within the scope of their official duties, to take 

endangered and threatened species without a permit, "to aid a sick, injured, or orphaned 

specimen," to "dispose of a dead specimen," to "[s]alvage a dead specimen which may be useful 

for scientific study," or to "remove specimens which pose a demonstrable but nonimmediate 

threat to human safety." 50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) (1993).

U.S. Forest Service

Under the Act of 1932, as amended, (7 U.S.C. 426-426c), the USFS and WS, along with the 

states, cooperate to manage animal damage on National Forest System lands. Under the 

framework of a 2011 MOU between the USFS and WS (Appendix B), WS is designated as the 

lead agency concerning animal damage management activities involving predators on National 

Forest System lands. This includes a responsibility to maintain technical expertise in the science 

of animal damage management, control tools and techniques, conducting management programs, 

and complying with the NEPA for activities related to predator damage management.

The USFS is responsible for the management of land and resources under its jurisdiction. The 

MOU directs the USFS to coordinate with WS in the development and annual review of wildlife 

damage management plans governing WS’ activities on National Forest System lands and to 

cooperate in WS’ NEPA processes. WS currently does not work on USFS lands, but could be 

requested to do so in the future. Work done on USFS lands would be conducted in coordination 

with the Regional Forester and under annual WDM work plans. 

Washington Endangered Species Act

The Washington ESA (WAC 232-12-297) provides protection for any wildlife species native to 

the state of Washington that is seriously threatened with extinction throughout all or a significant 

portion of its range within the state and any wildlife species native to the state of Washington 

that is likely to become an endangered species within the foreseeable future throughout a 

significant portion of its range within the state without cooperative management or removal of 

threats.

WDFW - Mandate (RCW 77.04.012)

RCW 77.04.012 mandates that “the commission, director, and the department [WDFW] shall 

preserve, protect, perpetuate, and manage the wildlife and food fish, game fish, and shellfish in 

state waters and offshore waters”. In part, this policy states that the WDFW shall conserve the 

wildlife and food fish, game fish, and shellfish resources in a manner that does not impair the 

resource and may authorize the taking of wildlife, food fish, game fish, and shellfish only at 

times or places, or in manners or quantities, as in the judgment of the commission does not 

impair the supply of these resources.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 18

CHAPTER 2. DESCRIPTION OF ALTERNATIVES

WDFW requested Wildlife Services (WS) to assist them with managing wolves and wolf 

damage. Without WS assistance, wolf damage management will be implemented by WDFW

according to the WCMPW (Appendix A). WS developed three reasonable alternatives in 

response to the request assist with wolf damage management in WA. The Current Program “No 

Action” alternative was evaluated for comparison to describe the environmental baseline. “No 

Action” means no change from the status quo. The status quo is that WS provides technical 

assistance and some non-lethal control methods to people in Washington asking for help. If WS 

selected the Current Program “No Action” alternative, WDFW would implement the WCMPW 

to the best of its ability, including lethal control of wolves (Appendix A). The second alternative 

is the Eliminate the Current Wolf Assistance Program alternative. This would prevent WS from: 

1) conducting any wolf damage management, 2) providing any technical assistance, and 3) 

assisting in public education and outreach of wolf issues. The Proposed Action Alternative, 

Expand the Current Wolf Assistance Program alternative, would allow WS to develop an 

integrated approach to respond to requests from WDFW, USFWS, and tribes to assist with 

several aspects of the WCMPW or similar guidance, including lethally removing wolves to 

enhance overall conservation and recovery efforts.

Within the limited decision space afforded WS by the WCMPW, WS has no regulatory authority 

or latitude to implement other approaches, nor can it require alternative actions/requests of 

WDFW, USFWS, or tribes.

2.1 Alternative 1 - No Action 

The Current Program “No Action” Alternative is for WS to continue its existing wolf damage 

management actions, as is. This is the environmental status quo, a required NEPA component, a 

viable alternative that could be selected, and serves as a baseline for comparing the action 

alternatives (CFR 1502.14[d]). Under this alternative, WS would continue its current activities 

conducting investigations of livestock conflicts, providing the public with advice and 

recommendations on the appropriate use of non-lethal methods to protect livestock from wolf 

damage, and performing select non-lethal control actions to reduce wolf damage. 

Wildlife Services assists and reports to WDFW and USFWS (in areas where wolves are federally 

listed) in conducting livestock damage investigations. When mortality events are determined to 

be caused by predation, they are investigated further to determine the species that caused the 

damage. If wolves may be potentially involved, WS coordinates investigation activities with 

WDFW/USFWS and/or other appropriate agencies.

Non-lethal methods currently recommended by the WS program include: radio-activated guard 

(RAG) devices, non-injurious harassment, non-lethal injurious harassment, fladry, range riders, 

animal husbandry practices, installation of fencing, and the use of livestock guarding animals.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 19

WS provides the results of confirmed, probable, and possible wolf conflict investigations to 

WDFW/USFWS, but would not provide lethal removal assistance to WDFW, USFWS, tribes, or 

livestock producers to alleviate confirmed wolf damages. WDFW stated that they would conduct 

the necessary actions as described in the WCMPW to remove repeated depredating wolves if the 

WS program were not available (Appendices A). Therefore, the Current Program “No Action” 

alternative must be evaluated as the conditions under which gray wolves are managed by 

WDFW.

The WCMPW describes measures the WDFW would take to conserve and manage wolves, 

including actions that could be taken to protect livestock from wolf depredation. The following 

summarizes the primary components of the WCMPW, but removes WS from conducting lethal 

removal or trapping of wolves for WDFW/USFWS under this “no action” alternative.

Under this alternative (No Action), WS would not conduct any trapping or lethal control. 

However, the following actions may still occur by other agencies and/or individuals:

 In areas where wolves are federally delisted but listed as a state endangered species under

WAC 232-12-297, the WCMPW allows for the following actions, which may be 

implemented by WDFW or its agents, USFWS, tribes, and WS (except for live trapping, 

relocation, and lethal removal):

o Non-injurious harassment: Livestock owners and grazing allotment holders (or their 

designated agents) will be allowed to harass wolves with non-injurious techniques when 

wolves are in close proximity to livestock or livestock grazing areas on private and public 

land. These techniques could include scaring off an animal(s) by firing shots or cracker shells 

into the air, making loud noises, or other methods of confronting the animal(s) without doing 

bodily harm.

o Non-lethal injurious harassment: This form of harassment involves striking wolves with nonlethal projectiles, such as rubber bullets specifically designed and approved for use on 

wolves, paintballs, and beanbags (Bangs et al. 2006). Livestock owners and grazing allotment 

holders (or their designated agents) may be issued a permit to use non-lethal injurious 

harassment on their own land or their legally designated allotment, respectively. WS would 

not apply injurious harassment toward wolves under this alternative.

o Relocate individual wolves: Relocating an individual wolf is a possible management tool to 

remove the animal from a conflict situation. This activity would be evaluated on a casespecific basis, but would especially be considered during endangered and threatened status. 

WS would not capture or relocate wolves under this alternative.

o Any relocation would be conducted by WDFW, or its agents, in consultation with the 

appropriate land management agency and the USFWS, if wolves are federally listed in that 

portion of the state.

o Lethal control to resolve repeated livestock depredations: WS would not conduct lethal 

removal under this alternative; however, lethal removal may be used by others to stop 

repeated depredation if it is documented that livestock have been killed by wolves, non-lethal 

methods have been tried but failed to resolve the conflict, depredations are likely to continue, 

and there is no evidence of intentional feeding or unnatural attraction of wolves by the 

livestock owner. In areas of Washington where wolves are federally listed, any proposal to 

lethally control wolves would have to be consistent with federal law. WDFW does not have 

authority to lethally remove wolves where they are federally listed. During state endangered 

and threatened status, lethal control would be conducted by WDFW or its agents. If a 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 20

situation were to occur where WDFW did not have the resources to address a situation of 

repeated depredations, WDFW may consider issuing a permit to a livestock owner to conduct 

lethal control during a specific time period on private lands they own or lease. 

o Lethal take in the act of attacking livestock: WS would not lethally remove wolves under this 

alternative. This provision allows lethal take of federally delisted wolves “in the act” of 

attacking livestock (defined as biting, wounding, or killing; not just chasing or pursuing) by 

livestock owners, family members, and authorized employees with an issued WDFW permit 

on private land they own or lease (including federal grazing allotments) during all state listed 

statuses. This provision would not be available in areas of the state where wolves are 

federally endangered. Federal law does not allow lethal take of an endangered species in the 

act of attacking livestock. At federal threatened status, there is more management flexibility 

through federal regulations. Wherever wolves are federally listed in Washington, the U.S. 

Fish and Wildlife Service is the lead management authority. In these areas, WDFW will 

consult with and collaborate with the U.S. Fish and Wildlife Service on management 

decisions and actions to ensure consistency with federal law. State law (RCW 77.15.120) 

prohibits the killing of an endangered species unless it has been authorized by rule of the 

commission. Subject to limitations established by the commission, certain private citizens 

may kill wildlife that is threatening human safety or causing property damage. Under RCW 

77.36.030, the conditions set by the commission must include “appropriate protection for 

threatened or endangered species.” It also states that in establishing the limitations and 

conditions related to wolves, the commission “shall take into consideration the 

recommendations of the Washington state wolf conservation and management plan.” Under 

WAC 232-36-051, it is unlawful to kill state endangered species causing damage to 

commercial livestock unless authorized by commission rule or WDFW permit.

 The federal Endangered Species Act provides that “...any person may take endangered wildlife in 

defense of his own life or the lives of others” (50 CFR 17.21(c)(2)). State law also makes it 

permissible to kill “...wild animals engaged in the physical act of attacking a person” (Chapter 

WAC 232-36-050(3)(a)). It is important to understand that wolves passing near, watching, or 

otherwise behaving in a non-threatening way near humans should not necessarily be considered 

as dangerous. Under these circumstances, wolves could and should be hazed using non-lethal 

methods; use of lethal force is unneeded and illegal.

 A strong information and education program is proposed to ensure anyone with an interest in 

wolves is able to learn more about the species and stay informed about wildlife management 

activities.

 Several research projects are identified as necessary for future success of long-term wolf 

conservation and management. Monitoring and radio-collaring wolves are listed as critical 

components of the WCMPW for conservation and communication with Washingtonians.

Based on experiences in other states, wolf depredation on livestock is expected to occur in 

Washington as wolves become reestablished. Resolving wolf-livestock conflicts will require 

non-lethal and lethal control responses. Resolution of conflicts will need to be managed in a way 

that does not jeopardize recovery of the species and is consistent with state and federal laws. 

This approach for managing a listed species is highly unusual, but is required because of the 

desire to reduce conflicts and build social tolerance for wolves, thereby enhancing the chances 

for reestablishing the species in the state.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 21

The WCMPW endeavors to provide as much flexibility to address conflicts as possible while still 

remaining focused on achieving wolf conservation goals. This incremental approach is designed 

to provide options to wolf managers, livestock producers, and the public while promoting the 

goal of conservation for wolves. The WCMPW provides that WDFW can authorize the killing of 

federally delisted wolves due to repeated livestock losses when the requester has documented 

unsuccessful attempts to solve wolf-livestock conflict with non-lethal methods.

Management approaches are based on the status of wolves, ensuring that recovery objectives are met. 

Non-lethal management techniques will be emphasized throughout the recovery period and beyond. 

Actively informing and equipping landowners, livestock producers, and the public with tools to 

implement proactive wolf damage management techniques will be an important aspect of this 

approach. Lethal control will be used only as needed after case-specific evaluations are made, with 

use becoming less restrictive as wolves progress toward delisting. WS would not conduct lethal 

removal under this alternative.

Currently, state laws RCW 77.36 and WAC 232-36 allow owners of commercial livestock (cattle, 

sheep, and horses held or raised by a person for sale) to be compensated by WDFW for animals 

killed or injured by bears, cougars, and wolves if required conditions are met. This plan provides for 

a state compensation program for documented confirmed and probable wolf-killed livestock in order 

to reduce the financial losses that some livestock producers might experience while wolves are state 

listed. Public support for a state-funded wolf compensation program was expressed in the comments 

received during public meetings in 2007 and 2009 and the plan’s public review period in 2009-2010. 

An effective compensation program supported by the public and Legislature can also help maintain 

tolerance for wolves among some landowners and livestock producers (Bangs et al. 2006, Stone 

2009), which can help decrease illegal killings and aid wolf recovery.

The role of WS under this alternative would be indirect: WS could provide advice to producers 

on the use of non-lethal methods, could investigate wolf damage incidents and report results to 

WDFW, and could conduct select nonlethal harassment. WDFW makes the final determinations.

2.1.1 Non-lethal Methods Available to WS, WDFW, USFWS, Tribes, and the Public

Some wolf damage management methods are available for anyone to use. These consist of nonlethal preventive methods such as cultural practices (e.g., possible changes in livestock 

management) and localized habitat modification (e.g., clearing brush, improving fencing, etc.) on 

private property. Cultural practices and other management techniques are implemented by the 

resource owners/managers. Livestock producers and resource owners/managers are encouraged 

to use these methods, based on the level of risk, need and professional judgment on their 

effectiveness and practicality. WS’, WDFW’s, or USFWS’ involvement in the use of these 

methods is usually limited to providing technical assistance.

Livestock Management Practices are implemented to prevent or reduce wolf damage and may 

include approaches such as: 1) maintaining healthy, well-fed animals, 2) properly disposing of 

livestock carcasses (i.e., removal, burying, liming, or burning), 3) conducting calving or lambing 

operations in close proximity to the ranch headquarters when practical, 4) penning vulnerable 

livestock at night where practical, 5) monitoring livestock on a regular basis to detect any 

disease, natural mortality, or predation, 6) keeping livestock away from areas of historic wolf 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 22

activity, and 7) incorporating other non-lethal methods. Property owners and land managers 

could implement these management practices or request the assistance of other agencies or 

private organizations to implement them, or take no action.

Exclusion with some type of fence or other barrier may be used to prevent or limit access by 

predators to livestock pastures, calving or lambing areas, or livestock confinement areas. Where 

practical and cost effective, sheep, calves, or other vulnerable livestock may be penned near 

ranch buildings at night.

Fladry is a form of barrier and wolf deterrent involving red flags measuring approximately 3 x 

18 inches, strung about 20 inches apart, hanging from a thin rope or cord suspended about 30 

inches above the ground. Fladry is installed around pastures or other areas where livestock are 

confined to discourage wolf access. Part of the repellency provided by fladry is probably related 

to the frequent human visitation required to ensure that the flags remain freely suspended and 

that the line is properly maintained. Like many other frightening devices, wolves eventually 

habituate to this deterrent, but field trials in Idaho have shown that fladry may provide deterrence 

for as long as 60 days (Musiani et al. 2003). Davidson-Nelson and Gehring (2010) reported that 

if maintained, fladry can exclude wolves from livestock for up to 75 days; however Shivik et al. 

(2003) found that fladry did not effectively protect bait sites from scavengers, including wolves.

Turbo-Fladry is very similar to regular fladry with the exception that the cord is substituted 

with electrified wire attached to a standard livestock electric fence generator. As wolves 

habituate to the fladry line and try to cross under it, the negative stimulus they receive after 

getting shocked by the electrified barrier can increase the amount of time the barrier may remain 

effective.

Livestock guarding animals such as large, aggressive breeds of guarding dogs (e.g., Great 

Pyrenees, Akbash, etc.) have been used with some success to protect livestock from wolves, but 

multiple guard dogs work better than just one or two guard dogs (Bangs et al. 2005, Urbigkit and 

Urbigkit 2010). Even with 3 or more dogs present, wolves occasionally kill or severely injure 

livestock guarding dogs. Livestock guarding dogs are generally not killed as prey but because of 

interspecies aggression (Bangs et al. 2005). Other types of livestock guarding animals, such as 

llamas, which have been shown in some circumstances to be effective in protecting sheep from 

coyotes, are not as effective in deterring wolves. Wolves probably view llamas as prey, and 

multiple instances of wolves killing and feeding on llamas have been documented in the NRM 

area (USFWS et al. 2003, 2008, 2009, and 2010).

Guarding and hazing involves using human presence to guard an area and then using 

pyrotechnics or other frightening devices to frighten wolves from the site if/when they arrive. 

Hazing can be used as an aversive technique, but requires that the technique be used consistently 

whenever the animal attempts to prey on the protected resource so they do not identify 

conditions when they can obtain prey without receiving a negative experience (Shivik 2004). If 

there are any radio-collared wolves in a pack which may pose a threat to livestock, non-lethal

hazing efforts can be enhanced if the livestock producer or other personnel make use of a radio 

receiver to determine when wolves are near or approaching the livestock (Bangs et al. 2006). 

This requires diligent and persistent monitoring, but can make hazing much more effective.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 23

Frightening devices are methods that usually involve lights, sound and/or motion devices 

designed to deter wolves from a certain area. Strobes and flashing lights, propane exploders, 

sirens, and various combinations of these devices have all been used in attempts to reduce 

livestock losses, with wide-ranging degrees of effectiveness (Linhart 1984, Andelt 1987). 

Animal habituation (becoming accustomed) to the stimulus is one of the primary limiting factors 

for repellents. Essentially, anything new or different is likely to elicit avoidance behavior by 

canids, but this effectiveness disappears over time. Moving the devices intermittently and 

randomly as well as alternating the stimuli (e.g., a different type of noise or light) may extend the 

effective period of the system (Shivik and Martin 2001). The period of efficacy may also be 

extended by using systems which are motion-activated or only activated when a wolf wearing a 

transmitter collar comes into close proximity to the protected site. The RAG box is one such 

frightening device that employs this approach, and RAG boxes have been field-tested in Idaho 

with some success (Breck et al. 2002). Use of the RAG box in Idaho has been most effective in 

protecting livestock in small (≤60 acre), fenced-in areas.

2.1.2 Non-lethal Methods Available to WDFW, USFWS, and Tribes, but not WS

Some non-lethal methods, research projects, and population monitoring efforts involve capture 

and handling wolves which may not be conducted by the general public. Methods that require 

capture and handling of wolves under state authority would only be conducted by WDFW

personnel or agencies permitted by the WDFW. Sovereign tribal governments could act under 

their own authority on sovereign tribal lands. 

Foot-hold traps can be effectively used to live capture wolves, and are an extremely important 

tool in wolf damage management. When wolves are trapped they are ordinarily physically 

restrained or chemically immobilized, radio-collared, and released on site, or euthanized on site. 

Effective trap placement, pan-tension devices and the selection and placement of appropriate 

lures and baits by trained personnel contribute to the foot-hold traps’ selectivity. Traps may also 

be modified with small protrusions or “nubs” on the jaws to reduce the likelihood of the wolf’s 

foot moving back and forth in the jaws, thereby reducing the potential for trap-related injury. 

Washington State has a trap check rule in effect requiring that all foothold traps be checked 

every 24 hours.

Disadvantages of traps include the difficulty of keeping them operational during rain, snow or 

freezing weather, and the fact that they cannot be 100% selective. Although pan-tension devices 

are effective in reducing the likelihood of unintentional capture of non-target species smaller 

than wolves (e.g., red fox, coyote), they cannot preclude the occasional capture of larger nontarget species such as cougars or black bears. They do, however allow for the option of releasing 

non-target animals which may infrequently be captured. 

Foot snares are devices consisting of a cable loop and a locking device that captures an animal 

around its foot or lower leg. The cable may be activated around the lower leg with a springpowered throw-arm (Aldrich-type) or trap-type (Belisle) device. The foot snare can be modified 

with a stop on the cable to restrict the closure of the loop. Careful snare placement, pan-tension 

devices and the selection and placement of appropriate lures and baits by trained personnel 

contribute to the selectivity of this device. As with foot-hold traps, when foot snares are used as 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 24

a live-capture device, wolves would ordinarily either be radio-collared and released on site, or 

euthanized. Foot snares are more often used for capture of cougars and black bears than for 

wolves. Washington State has a trap check rule in effect requiring that all foot snares be checked 

every 24 hours.

Drug delivery tools are capture tools that utilize a dart or syringe filled with an immobilization 

drug, dispensed from a specially-designed device. These devices include hand or poll syringes, 

blow guns, and compressed gas or gun-powder charged systems. They would often be used on 

wolves when conducting live-capture operations from a helicopter. Once immobilized, the 

animal may be handled safely and processed for research or monitoring purposes. Use of drug 

delivery tools would have no effect on non-target species because positive target species 

identification is made before animals are darted. 

Neck Snares can be used to kill, or to live-capture animals with a cable loop around the neck 

and the use of a “stop” to prevent full closure of the loop. Improved methods for use are being 

developed for live-trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 

are ordinarily not as affected by rain, snow, and freezing weather as foot-hold traps are. These 

devices offer a degree of selectivity based on the size of the cable loop and the height of the loop 

above ground level. They also offer a viable live-capture alternative to foot-hold traps during the 

winter months, when freezing temperatures combined with restricted blood circulation could 

result in damage to the wolf’s foot.

2.1.3 Non-lethal Methods which may Require Special Authorization from WDFW, 

USFWS, and Tribes

These methods are not available to WS under this alternative (Alternative 1, NO Action). Some 

animal behavior modification systems involve capturing and fitting wolves with radiotransmitting collars to deliver or trigger repellent stimuli (i.e., aversive conditioning). Other 

systems sometimes referred to as “less than lethal munitions,” involve shooting wolves with 

projectiles such as rubber bullets or bean bag rounds. These techniques involve intentionally 

using painful stimuli to modify wolf behavior and WDFW and the USFWS may require permits 

or other authorizations to use these methods and any other experimental wolf damage 

management techniques. Methods that require capture and handling of wolves would be 

conducted only by personnel from WDFW, USFWS, or tribes, and / or personnel authorized by 

either of these entities.

Aversive Stimuli are stimuli that cause discomfort, pain and/or an otherwise negative experience 

paired with specific behaviors to achieve conditioning against these behaviors. One example 

would be using something like a dog training shock collar that is activated when wolves come 

into close proximity to a protected area such as livestock pens (Shivik et al. 2003, Schultz et al. 

2005).

Non-lethal Projectile use involves guarding an area and then using rubber bullets, bean bag 

rounds or other non-lethal projectiles to prevent a predation event. They can be used as an 

aversive technique, but require that the projectiles be used consistently whenever the predator 

attempts to prey on the protected resource, so it is less likely to identify conditions when it can 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 25

obtain prey without receiving a negative experience (Shivik 2004). Methods which require 

around-the-clock presence of a person to guard the resource are most efficiently used when there 

are radio-collared wolves involved and the landowner/resource manager assists with the 

implementation. WDFW authorizes the use of these methods.

For additional discussion of the advantages and disadvantages of various non-lethal and lethal 

wolf damage management methods used in the NRM, see Bangs et al. (2006) 

(http://www.aphis.usda.gov/wildlife_damage/nwrc/publications/06pubs/shivik067.pdf).

2.1.4 Description of Lethal Methods Available to WDFW, USFWS, and Tribes, but not 

WS

These methods are specifically designed to lethally remove wolves in certain situations to 

stabilize, reduce, or eliminate damage. The amount of removal necessary to achieve a reduction 

in wolf damage varies according to the effectiveness of other damage management strategies, the 

damage situation, and the level and likelihood of continued depredations. There would be no 

lethal wolf damage management techniques available to WS under Alternative 1, but the use of 

foothold traps and snares, as described above, followed by euthanasia, typically by gunshot to 

the brain, as recommended by the American Veterinary Medical Association (AVMA 2013, 

Julien et al. 2010) would be available to WDFW or its agents, USFWS, and tribes. Additional 

lethal methods used under Alternative 1 would include shooting from the ground as well as from 

fixed-wing aircraft or helicopters.

Shooting from the ground is highly selective for the target species, and may be employed in 

conjunction with the use of auditory attractants (e.g., sounds of prey animals in distress or 

imitations of wolf vocalizations). Removal of one or two specific animals by shooting in the 

problem area can sometimes provide immediate relief from a predation problem. Shooting is 

often tried as one of the first lethal management options because it offers the potential of solving 

a problem more quickly and selectively than some other techniques, but it requires visually 

sighting the wolf within effective shooting distance. Shooting may sometimes be one of the only 

management options available if other factors preclude the setting of equipment (i.e., traps or 

snares).

Aerial Shooting typically involves visually locating suspected depredating individuals or packs 

from either a small single-engine fixed-wing aircraft or a helicopter, and shooting them from the 

aircraft. Depredation problems can sometimes be resolved very quickly and effectively through 

aerial shooting (e.g., by starting the aerial operation in the vicinity of a recent wolf kill and 

catching the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) 

rated aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of 

adverse environmental impacts. Smith et al. (1986) cited cost-effectiveness and efficacy as 

benefits of aerial shooting.

Good visibility is required for effective and safe aerial shooting operations, and relatively clear 

and stable weather conditions are necessary. Summer conditions limit the effectiveness of aerial 

shooting because the increased vegetative cover makes finding the animals more difficult, and 

the higher ambient air temperatures reduce air density, which affects low-level flight safety.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 26

Aerial shooting is one of the most effective wolf damage management tools available.

Sodium Pentobarbital (Beuthanasia®-D) is registered for euthanasia of dogs, but may legally 

be used for other animals if the animal is not intended for human consumption. Barbiturates 

depress the central nervous system in descending order, beginning with the cerebral cortex, with 

unconsciousness progressing to death. The primary advantage of barbiturates is the speed of 

action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the 

animal (AVMA 2013). This method of euthanasia would likely only be used in the rare 

circumstance where an already sedated wolf was determined to have health or injury issues such 

that it would be most appropriate to euthanize the animal.

2.1.5 Monitoring

WS provides information on wolf sightings, identification of wolf activity (tracks or scat), 

depredation investigations, telemetry searches, or any other monitoring activities. Wildlife 

Services monitors its program activities using a national software program, Management 

Information System (MIS), which compiles data on harassment locations, damages, methods

used, and other information. Information from MIS can then be provided to cooperating 

agencies, used in wildlife management decisions and environmental analyses, and is available to 

the public.

2.2 Alternative 2 – Eliminate the Current Wolf Assistance Program

Under Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 

not provide any wolf assistance to WDFW, USFWS, other public agencies, tribes, or private 

individuals within Washington. WS would not distribute available equipment or assist 

landowners with the implementation and use of non-lethal methods and devices. WS would not

investigate wolf depredation complaints to determine if the wolves are responsible for losses. 

WDFW would make the final determinations for investigations under their jurisdiction. WS 

would not assist WDFW, USFWS, or tribes with capturing wolves for radio-collaring for 

monitoring purposes and/or to enhance effectiveness of non-lethal deterrents such as the RAG

devices. 

The WCMPW describes measures WDFW would take to conserve and manage wolves, 

including actions that could be taken to protect livestock from wolf depredation. Alternative 2 

encompasses all the primary components of the WCMPW and all actions and components listed 

in Alternative 1, but removes WS as an assisting agency to WDFW, USFWS, and tribes. While 

the WCMPW references WDFW using WS for assisting with wolf recovery, WS would not

actually participate in any wolf-related actions under this alternative. WDFW, or its agents,

would have to redirect personnel from conducting wolf research, outreach, and recovery projects 

to conducting wolf control and removal. WS would not be able to guarantee any mitigation 

measures against the accidental impact to target and non-target wildlife, public safety, or 

personnel safety during wolf control activities conducted by others.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 27

2.3 Alternative 3 – Proposed Action Alternative – Expand the Current Wolf Assistance 

Program

This alternative would allow WS to use non-lethal methods, capture wolves for monitoring or 

translocation needs, and respond to requests by WDFW or tribes to lethally remove non-federally 

listed depredating wolves, and with the addition of USFWS, wolves jeopardizing public safety as 

outlined in the WCMPW or similar guidance (e.g., ESA and CFR). Wolves could be removed 

after a request from WDFW or tribes based on confirmed livestock depredation and after 

unsuccessful attempts using non-lethal methods had been documented. The Proposed Action

Alternative encompasses all of the methods discussed in Alternative 1 with WS conducting the 

direct activities. 

The role of WS in this program would be direct: WS would conduct a fully integrated approach 

to wolf damage management, as requested by WDFW, USFWS, or tribes under the guidance of 

the WCMPW or similar guidance. WDFW would maintain responsibility for making the final 

determinations on removal of federally delisted wolves, USFWS would retain management of 

federally listed wolves, and tribes would maintain management of wolves on tribal lands. WS 

wolf damage management on tribal lands would mirror procedures and restrictions on non-tribal 

lands, with the exception that tribal wildlife managers or WS may confirm wolf damages.

As per WS policy, it would only provide direct wolf damage management on properties after 

Agreement for Control or other work authorization documents have been completed. On federal 

public lands, planned activities must be included in work plans developed in coordination with 

each National Forest or BLM Resource Area, or in emergency, unplanned situations, in 

consultation with the respective USFS or BLM office. On tribal reservation lands, WS wolf 

damage management would only be conducted at the request of the tribe and under individual 

agreements with each sovereign tribal government.

Like Alternative 1, the Current Program, a strong information and education program, which 

focuses on nonlethal management, would be managed by WDFW with assistance from WS. 

This aspect would help ensure anyone with an interest in wolves is able to learn more about the 

species and stay informed about wildlife management activities. The WCMPW includes 

examples of education on wolf damage management issues such as public outreach, public 

meetings, information on the WDFW website, training, and discussions with individuals.

Several research projects are identified as necessary for future success of long-term wolf 

conservation and management. Monitoring and radio-collaring wolves would be included in this 

alternative for conservation and communication with the public. WS may assist in capturing 

wolves for radio-collaring.

Adaptive management would be used by WDFW to revise protocol according to changes in the 

phase of wolf recovery in Washington. Over time, wolves are expected to increase in number 

and expand their range within Washington, and therefore management approaches will be 

slightly modified as numbers increase (Wiles et al. 2011).
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 28

Finally, the WCMPW requires annual reporting to the WDFW on program implementation, thus 

WS would provide all information on its involvement with wolf captures including capture 

locations, methods used, and disposition to WDFW. 

2.3.1 Formulating a strategy for wolf removal

Upon receiving a request to assist WDFW, USFWS, or tribes with capturing individuals from 

packs with confirmed repeated depredating wolves, WS would use its Decision Model (Figure3) 

(Slate et al. 1992) to determine the appropriate method of removal based on allowable methods 

(foot-hold traps, foot snares, neck snares, shooting, or aerial shooting) under the WCMPW, or 

similar guidance, and consultation with WDFW, USFWS, or tribes.

Figure 3. APHIS-WS Decision Model (Slate et al. 1992)

In selecting appropriate management techniques, consideration is given to: whether or not a 

collared or breeding wolf could be affected, location and land jurisdiction; land uses (such as 

proximity to urban or recreation areas); possible presence of humans, pets and non-target 

wildlife; feasibility of implementation of the various techniques; wolf movement patterns and 

life cycle; local environmental conditions such as terrain, vegetation, and weather; potential legal 

restrictions such as availability of tools or management methods; humaneness of the available 

options; and costs of control options (the cost of control in this proposal may be a secondary 

concern because of overriding environmental, management, and legal considerations).

When responding to requests from WDFW or tribes, lethal removal of wolves from packs 

causing repeated livestock depredation would only be done after unsuccessful attempts to use 

non-lethal methods had been documented. While the WCMPW dictates this for WDFW, WS 

would only agree to lethal removal on tribal lands under similar guidance.

2.3.2 Description of Lethal Methods Available to WS

This alternative includes all non-lethal methods described in Alternative 1, the Current Program, 

and adds the following lethal methods. These methods are specifically designed to lethally 

remove problem wolves in certain situations to stabilize, reduce, or eliminate damage. The 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 29

amount of removal necessary to achieve a reduction in wolf damage varies according to the 

effectiveness of other damage management strategies, the damage situation, the level and 

likelihood of continued depredations, and WDFW or tribal final decision. The lethal wolf 

damage management techniques available to WS would include the use of foothold traps and 

snares, followed by euthanasia, as recommended by the American Veterinary Medical 

Association (AVMA 2013, Julien et al. 2010). Additional lethal methods used under Alternative 

3 (the Proposed Action Alternative) would include shooting from the ground as well as from 

fixed-wing aircraft or helicopters.

Shooting highly selective for the target species, and may be employed in conjunction with the 

use of auditory attractants (e.g., sounds of prey animals in distress or imitations of wolf 

vocalizations). Removal of one or two specific animals by shooting in the problem area can 

sometimes provide immediate relief from a predation problem. Shooting is often tried as one of 

the first lethal management options because it offers the potential of solving a problem more 

quickly and selectively than some other techniques, but it requires visually sighting the wolf 

within effective shooting distance. Shooting may sometimes be one of the only management 

options available if other factors preclude the setting of traps or snares.

Aerial Shooting typically involves visually locating suspected depredating individuals or packs 

from either a small single-engine fixed-wing aircraft or a helicopter, and shooting them from the 

aircraft. Depredation problems can often be resolved quickly and effectively through aerial 

shooting (e.g., by starting the aerial operation in the vicinity of a recent wolf kill, and catching 

the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) rated 

aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of adverse 

environmental impacts. Smith et al. (1986) cited cost-effectiveness and efficacy as benefits of 

aerial shooting.

Good visibility is required for effective and safe aerial shooting operations, and relatively clear 

and stable weather conditions are necessary. Summer conditions limit the effectiveness of aerial 

shooting because the increased vegetative cover makes finding the animals more difficult, and 

the higher ambient air temperatures reduce air density, which affects low-level flight safety.

Aerial shooting is one of the most effective wolf damage management tools available.

Neck Snares can be used to kill, or to live-capture animals with a cable loop around the neck 

and the use of a “stop” to prevent full closure of the loop. Improved methods for use are being 

developed for live-trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 

are ordinarily not as affected by rain, snow, and freezing weather as foot-hold traps are. These 

devices offer a degree of selectivity based on the size of the cable loop and the height of the loop

above ground level. They also offer a viable capture alternative to foot-hold traps during the 

winter months, when freezing temperatures combined with restricted blood circulation could 

result in damage to the wolf’s foot.

Sodium Pentobarbital (Beuthanasia®-D) is registered for euthanasia of dogs, and may legally 

be used for other animals if the animal is not intended for human consumption. Barbiturates 

depress the central nervous system in descending order, beginning with the cerebral cortex, with 

unconsciousness progressing to death. The primary advantage of barbiturates is the speed of 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 30

action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the 

animal (AVMA 2013). This method of euthanasia would likely only be used in the rare 

circumstance where an already sedated wolf was determined to have health or injury issues such 

that it would be most appropriate to euthanize the animal.

2.3.3 Measures used by WS to Minimize Environmental Risk

WS uses many standard operating procedures built into its programs which serve to minimize the 

potential for negative effects on the environment, including potential harm to humans and nontarget wildlife. While the WCMPW may be updated and permit conditions can change, 

currently, WS standard operating procedures, the WCMPW and/or WDFW permit conditions 

and conservation measures include, but are not limited to the following measures:

 Conspicuous, bilingual warning signs alerting people to the presence of traps and snares are 

placed at major access points when they are set.

 WS personnel are trained in identification of wolves and wolf sign.

 WS will maintain regular contact with appropriate state and federal agencies, reporting any 

sightings of wolves, wolf sign, or wolf depredations.

 WS will monitor traps every 24 hours while using foothold traps or snares.

 WS will incorporate pan-tension devices in foot/leg snares and foot-hold traps to reduce 

exposure of capture to smaller non-target animals. 

 WS will maintain regular contact with WDFW, USFWS, and/or tribes to keep apprised of 

locations and information on the presence of any T&E animals.

 Most wolf trapping will occur at or near depredation sites or along wolf trails to and from 

depredation sites. 

 Non-target animals captured are released at the site of capture unless the WS personnel

determine that they will not survive.

 AVMA (2013) recommended euthanasia procedures are followed, if feasible, to minimize 

pain and suffering. 

 Research continues to improve the selectivity and humaneness of management devices.

 WS work on Native American Indian tribal lands would conform to tribal government 

plans for wolf damage management. WS work on tribal lands would also closely mirror 

protocol outlined in WCMPW in regards to lethal and non-lethal management of wolf 

depredation.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 31

 WS records and monitors all WS wolf removal through its Management Information 

System (MIS). Close coordination with and reporting to WDFW, USWFS, and/or tribes would 

occur for each wolf to be removed. More detail is provided under Monitoring in this section.

 Motorized vehicle access on public lands will be limited to permitted roads and areas. 

 Wolf damage management activities would be conducted only at the request of, and in 

coordination with the landowner or land management agency, and in the case of lethal control, 

per WDFW, USFWS, or tribal government decisions. Coordination provides for the 

communication necessary to avoid conflicts with land uses such as sensitive areas or public 

safety zones.

 The WS program is conducted under Cooperative Agreements and MOUs with federal and 

state agencies. National MOU’s with the BLM (1995) and USFS (2010) delineate expectations 

for wildlife damage management on public lands administered by these agencies.

General Measures to Protect Federally Threatened or Endangered Species

 In accordance with WS policy, foot-hold traps and foot snares would be placed 

farther than 30 feet from exposed carcasses to avoid inadvertent capture of 

eagles.

 WS WA would prioritize control methods to be used and would include 

consideration of non-target species in making these decisions. Where nontarget species of concern may be vulnerable, selective measures are generally 

preferred (such as shooting or darting). For large animals, culvert or cage traps 

may be preferred over other trapping methods. Foot-hold traps and foot snares

are generally preferable to neck snares except under certain environmental 

conditions. WS WA will fully consider risk to non-target species in making 

these decisions.

 When conducting trapping, WS WA staff will consider target species, nontarget species, site-specific conditions, as well as all policy and regulatory 

requirements in determining types of traps, sets, lures or scents, and supporting 

hardware. The decision on whether to use a drag or stake will follow the 

considerations discussed earlier in the project description. 

 WS WA staff that are trapping large predators (e.g., wolves, cougars, and black 

bears), in areas where and when grizzly bear are reasonably likely to be present, 

will be trained in the identification of large predators (particularly in 

distinguishing between black bears and grizzly bears) and their sign. Training 

conducted by WS WA may be done in collaboration with the local USFWS or 

WDFW offices, or in conjunction with WS in other states. 

 Mapped landscape areas (designated for pygmy rabbit, lynx, grizzly bear, or 

federally listed wolves) will be reviewed on an annual basis with USFWS, 

WDFW, and other appropriate species experts to determine if an increase, 

decrease, or other modification is necessary. Applicable section 10(a)(1)(A) 

permits will be reviewed at that time to ensure continued applicability and 

listing of appropriate staff.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 32

 Prior to trapping within mapped landscape areas (designated for lynx, grizzly 

bear, or federally listed wolves), WS WA will contact USFWS and/or WDFW 

for the most-recent information regarding the distribution of these species. WS 

WA will conduct pre-trapping reconnaissance in a manner that is directed 

toward finding sign of these species and will report any positive findings to 

WDFW and USFWS. Personnel conducting such pre-trapping reconnaissance 

will be adequately trained in the identification of sign left by these species.

 Where pre-trapping reconnaissance discovers recent signs of certain species, or 

pre-trapping coordination reveals recent reliable observations of those species 

(i.e., grizzlies or lynx), alternative methods that are more selective will be used 

in lieu of trapping unless otherwise approved on a case-by-case basis by the 

USFWS after considering public safety and animal welfare.

 When trapping in grizzly bear, lynx, or federally listed wolf mapped landscape 

areas, or trapping for federally listed wolves, traps or snares should be checked 

by mid-morning, or as soon thereafter as possible in case of extenuating 

circumstances.

Measures Specific to Federally Listed Gray Wolves

 When doing pre-trap or operational reconnaissance for federally listed wolves 

and sign in areas that may contain wolves, howling will be conducted to 

facilitate detection if it is appropriate for the surroundings.

 While targeting coyotes and other predators, and where pre-trapping 

reconnaissance discovers recent sign or pre-trapping coordination reveals recent 

reliable observations of federally listed wolves, WS WA may resort to nontrapping alternatives to achieve their objectives if capture of a wolf in that area 

is not deemed to be desirable. When capture of a wolf is deemed desirable by 

WS WA and wildlife agencies, WS WA will follow appropriate protocols 

provided by the wildlife agencies and all conservation measures that apply in 

case they inadvertently capture a wolf.

When operating within a mapped landscape area for federally listed wolves, WS 

will implement the following:

 Initial mapped landscape areas for federally listed wolves shall be the pack 

polygons maintained by WDFW and depicted on the WDFW website 

(http://wdfw.wa.gov/conservation/gray_wolf/packs/). These may change on 

a frequent basis as wolf distribution changes. Whether this system is 

working adequately will be assessed on an annual basis.

 Prior to controlling coyotes and other predators, WS WA would coordinate 

closely with USFWS and/or WDFW to ensure that field personnel have the 

most recent and most-reliable information on wolf activity in the action 

area. WS WA would conduct pre-trapping reconnaissance in a manner to 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 33

detect any potential wolf sign prior to setting traps; this may include 

howling when appropriate. 

 When controlling predators smaller than wolves, traps and equipment must 

be of sufficient strength to adequately restrain any wolf without equipment 

failure, or allow the wolf to pull free from the trap. Stakes will be preferable 

in these situations as staking may allow a captured wolf to pull-out of the 

trap more easily.

 When conducting predator control, no traps or snares shall be used within 

0.5 mile of occupied federally listed wolf den sites, known active 

rendezvous sites, or areas of recently documented pup activity from May 1 

to July 15, and within 1 mile of these areas from July 15 to October 1, 

unless approved on a case-by-case basis by the USFWS. 

 When conducting predator control, neck snares will not be used in mapped 

landscape areas without prior approval by USFWS.

When trapping federally listed wolves, WS will implement the following: 

 No traps or snares shall be used within 0.5 mile of occupied federally listed 

wolf den sites, known active rendezvous sites, or areas of recently 

documented pup activity from May 1 to July 15, and within 1 mile of these 

areas from July 15 to October 1, unless approved on a case-by-case basis by 

the USFWS. 

 Neck snares will not be used to capture federally listed wolves unless such 

use is approved by USFWS.

 Foot-hold traps will not be used to capture federally listed wolves in 

nighttime temperatures below 25°F unless otherwise approved by USFWS.

 When live capturing federally listed wolves, WS WA will use Livestock 

Protection Company #7 offset jaws or EZ-grip®traps or equivalent, unless

otherwise approved by the USFWS. At least 2 swivels will be used (one at 

trap and one at drag or stake).

 WS WA will ensure, in advance, that a means of safe transport for federally 

listed wolves (e.g., a large kennel) is readily available if medical treatment 

should be necessary. 

 WS WA staff that capture federally listed wolves will be trained in chemical 

immobilization and handling of wolves, or will be accompanied by WS WA 

staff that have been so trained.

 This consultation will not supplant or replace any other reporting 

requirements or informational commitments. WS will adhere to any 

guidelines and protocols cooperatively developed among WS WA, WDFW, 

and USFWS regarding responding to sightings, captures, mortalities, 

information about illegal activities, or other reports of gray wolves in 

Washington State. 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 34

 When WS WA purposefully or incidentally captures federally listed wolves, 

in addition to adhering to the Response Guidelines, such capture will be 

managed in the following manner: 

o If the wolf is dead, WS will transport the carcass from the field and 

report the death to the USFWS Washington Fish and Wildlife Office 

within 24 hours for data collection and disposal. The carcass will be 

kept as cold as feasible to preserve its integrity.

o If the wolf will not be able to survive in the wild and should be 

euthanized on site, the most-expedient means of euthanasia shall be 

employed consistent with the surroundings and situation. Following 

euthanasia, WS will transport the carcass from the field and report to 

the USFWS Washington Fish and Wildlife Office so that they can 

cooperatively collect data and dispose of carcass. The carcass will 

be kept as cold as feasible to preserve it integrity.

o If the wolf requires veterinary medical attention and transport is 

necessary and feasible, WS will pursue veterinary medical care and 

notify the USFWS Washington Fish and Wildlife Office for 

instructions regarding the best course of action following such care. 

If the wolf is a candidate for release, the details of such release shall 

be determined cooperatively with the WDFW and the USFWS.

o If the wolf is essentially uninjured and is a good candidate for further 

research, WS will follow protocols provided by the USFWS and 

WDFW for collecting samples, data, and any fitting with 

instrumentation. Chemical immobilization shall only be done by 

personnel experienced with handling wolves and certified to 

administer chemical immobilization drugs, unless otherwise 

approved by USFWS. 

o If the wolf is uninjured and no research is needed, WS will release 

the wolf as expeditiously as possible in a manner that protects the 

wolf and maximizes its chances for successful release and survival. 

Steps outlined in applicable protocols shall be followed. In some 

cases, this may require restraint and or chemical immobilization. 

Chemical immobilization shall only be done by personnel 

experienced with handling wolves and certified to administer 

chemical immobilization drugs, unless otherwise approved by 

USFWS.

Measures Specific to Grizzly Bear

 When conducting predator control and where pre-trapping reconnaissance or 

pre-trapping coordination with USFWS or WDFW reveals sign of grizzly bear 

or recent reliable observations, WS WA would resort to non-trapping 

alternatives to achieve their objectives unless otherwise approved on a case-bycase basis by the USFWS after considering public safety and animal welfare.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 35

 WS WA staff conducting trapping for large predators (wolves, cougars, or black 

bears) in areas where and when grizzly bear are expected to be present will 

carry a copy of a grizzly bear protocol including contact numbers and will 

follow its instructions in the event a grizzly bear is captured. In the event that 

WS WA captures a grizzly bear, WS WA shall contact USFWS [Grizzly Bear 

Coordinator at (406) 240-6506] and an appropriate representative from WDFW. 

Arrangements would then be made to provide personnel from USFWS and/or 

WDFW to assist with handling the bear and determining the fate of the animal 

following the interagency guidelines already in place for recovery areas.

When operating within the grizzly bear mapped landscape areas during times 

that grizzly bears are expected to be out of the den (1 April to 30 November), 

WS WA will implement the following:

 Initial mapped landscape areas for grizzly bear will be the federal lands 

within the North Cascades Recovery Zone; all lands within WDFW Game 

Management Units 108, 111, and 113; and all lands within the “Wedge” 

(named after the wedge-shaped part of northwestern Stevens County on the 

Canadian border between the Kettle and Columbia Rivers)(Game 

Management Unit 105). The mapped landscape areas and measures 

followed within those areas may increase, decrease, or change on an annual 

basis following review with the wildlife agencies and others. 

 WS WA would contact WDFW and USFWS to obtain most-recent grizzly 

distribution information. 

 WS WA would conduct pre-trapping reconnaissance in a manner sufficient 

to detect any potential grizzly sign prior to setting traps. Where pre-trapping 

reconnaissance discovers recent signs of grizzly bear or pre-trapping 

coordination reveals recent reliable observations, WS WA would resort to 

non-trapping alternatives to achieve their objectives unless otherwise 

approved on a case-by-case basis by the USFWS after considering public 

safety and animal welfare.

 WS WA staff participating in trapping of large predators (wolves, cougars, 

or black bear) will be trained in the identification of grizzly bears 

(particularly in distinguishing between black bears and grizzly bears) and 

grizzly bear sign. 

 Staff participating in trapping of large predators (wolves, cougars, or black 

bear) will be trained in implementation of techniques to avoid accidentally 

trapping grizzly bears.

 WS WA staff conducting capture of large predators (wolves, cougars, or 

black bear) will have been trained in chemical immobilization and in 

handling of large predators, or will be accompanied by WS WA staff that 

have been so trained.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 36

 Use of foot snares and foot-hold traps for wolves, cougars, or black bears

will be limited. 

o WS WA would prioritize the methods to be used with more-selective 

methods (e.g., shooting or aerial darting) being preferable. 

Generally, more-selective measures are attempted first in an overall 

step-wise progression of control. 

o If no recent sign or knowledge of recent observations exists, WS 

WA may use foot snares and/or foot-hold traps within the mapped 

landscape area. WS WA would provide written notification to 

USFWS (electronic mail is acceptable) in advance (or within 72 

hours if advance notice is not possible) that would include 

demonstration of why such use is necessary in that particular 

situation as well as any prior methods that were attempted during the 

current control effort. 

o WS WA will report, annually, the extent and results of such 

trapping, the rationale for the use of foot-hold traps or foot snares, 

any prior methods that were attempted, and the timing and extent of 

coordination with USFWS. 

o Such notifications will not be necessary when trapping wolves 

within the range of the federally listed wolf because coordination 

and notification will occur concurrently with the USFWS request to 

do such work.

 Neck snares will not be used for any species without prior approval on a 

case by case basis by USFWS, except for trapping coyotes within the

following developed areas such as airports, urban/suburban developments, 

and animal-husbandry operations. For purposes of this measure, animalhusbandry operations include, for example, barnyards, corrals, poultry 

operations, animal enclosures, and similar operations near houses. When 

used in these situations, neck snares will be placed judiciously to avoid areas 

a grizzly bear or cub could reach or access. Appropriate neck snare 

locations may include coyote crawl-ways under fences or buildings.

 When using formulated or commercial scents at trap sites, WS WA would 

utilize scents that are less attractive to grizzly bears (e.g., wolf urine vs. 

scents resembling natural bear foods).

 Where possible and practical, wolf traps would be anchored to a solid 

anchor such as a tree or, if such anchorage is not possible, to drags of at 

least 500 pounds dead weight or Livestock Protection Company®heavyduty drag. 

 If foot snares are used for the capture of black bears, wolves, or cougars, all 

snares used will be grizzly sized snares with 1⁄4-inch steel cables anchored to 

fixed positions, and equipped with appropriate swivels. This is to ensure 

that if a grizzly bear is unintentionally captured the snare will hold the 

animal (rather than breaking away from the anchor and the grizzly bear 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 37

escaping with the snare remaining on the leg) until it can be safely 

immobilized and released. 

2.3.4 Monitoring

Wildlife Services role in monitoring would be to provide data to WDFW, USFWS, or tribes from 

its wolf damage management actions in Washington. Additionally, WS would provide 

information on wolf sightings, identification of wolf activity (tracks or scat), depredation 

investigations, telemetry searches, or any other monitoring activities. Wildlife Services monitors 

its program activities by using MIS, which compiles data on take locations, damages, methods 

used, and other information. Information from MIS can then be provided to cooperating 

agencies, used in wildlife management decisions and environmental analyses, and is available to 

the public.

2.4 Summary of Actions allowed by Alternative 

Table 1. Summary of WS activities that would be applied under each alternative (Adapted 

from WCMPW (Wiles et al. 2011, Table 9).

Activities

Alt. 1,

No 

Action

Alt. 2, 

Eliminate the 

Program

Alt. 3, 

Proposed 

Action

Alternative

Investigate Wolf Depredation for WDFW, 

USFWS, and tribes.

Yes No Yes

Non-lethal Technical Assistance (advice and 

information).

Yes No Yes

Non-lethal Direct Assistance (non-injurious 

harassment).

Yes No Yes

Non-lethal Direct Assistance (injurious 

harassment).

No No Yes

Lethal removal of non-federally listed wolves 

involved in repeated livestock depredation, as 

directed by WDFW or tribal authority.

No No Yes

Lethal removal of wolves that threaten human 

safety (per WDFW, USFWS, tribal, and/or ESA 

guidance).

No No Yes

Non-lethal capture for relocation, collaring, 

research, and/or monitoring. No No Yes

Assist WDFW, USFWS, and tribes with Wolf 

Monitoring.

Yes No Yes

Table 1 identifies and compares the major components allowed under each of the alternatives. 

Specific criteria or conditions for actions, as required by the WCMPW, are summarized under 

the detailed descriptions of each alternative.
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 38

2.5 Alternatives Considered but Rejected from Detailed Analysis, with Rationale 

Integrated Wolf Damage Management without a Threshold of Loss Requirement

This alternative would differ from the Proposed Action Alternative in that it would have 

removed the threshold of livestock loss imposed by the WCMPW for agency removals of 

confirmed repeated depredating wolves. Under this alternative, WS would be able to remove 

wolves that simply threatened livestock or had killed fewer than the allowed threshold of loss. 

This alternative is not a viable alternative and cannot be selected based on the direction outlined 

in the WCMPW. Wolves are not yet sufficiently abundant in Washington to allow for more 

liberal removal actions and all actions must conform to the strategies allowed by the state. There 

is some flexibility in the WCMPW that would allow producers to take wolves under permit 

which enhances agency actions. This alternative may interfere with WDFW’s ability to achieve 

wolf conservation and management goals.

Use of Birth Control Strategies to Reduce Wolf Depredation on Livestock

Under this alternative, wolves would be sterilized or other contraceptive methods would be 

administered to limit the ability of wolves to produce offspring under the assumption that 

inability to reproduce would reduce wolf depredation on livestock. This strategy may interfere 

with WDFW and USFWS goals for conservation and delisting of gray wolves. In USDA 

(2011a), WS considered wolf contraception strategies that involve removal of all wolves in a 

pack that had caused repeated livestock depredation with the exception of the breeding pair, 

which would be live-captured, surgically sterilized, radio-collared, and released under the 

assumption that the pair would maintain and defend its territory against other wolves. WDFW

has not considered or included any wolf contraception strategies in the WCMPW, nor does WS 

have the authority to implement or require WDFW or the USFWS to test or implement such 

strategies.

Eradication

This alternative would direct all WS program efforts toward planned, total elimination of wolves. 

This alternative was not considered in detail because eradication of established wolf populations 

is contrary to state and federal efforts to protect and conserve wildlife and contrary to federal and 

state ESA requirements, WS objective is to reduce damage, not to engage in large-scale 

eradication or suppression, and eradication of wolves is not acceptable to most members of the 

public.

Agencies Exhaust All Non-lethal Methods Before Attempting Lethal Methods

Under this alternative, all non-lethal methods would have to be attempted and proven ineffective 

prior to using lethal wolf damage management methods even though, in the professional 

judgment of WS, WDFW, or USFWS personnel, some methods that would have to be attempted 

would be impractical (e.g., would incur costs in excess of value of resources protected), 

inappropriate (e.g., use of a light siren device in areas near human residences), or likely to be 

ineffective for the particular situation (e.g., situations where the predator appears to have 
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 39

habituated). This alternative will not be addressed in detail for a number of reasons including: 1) 

time and resources of agencies and individuals experiencing damage may be unnecessarily 

expended when non-lethal methods are unlikely to be effective, based on circumstances, 

experience and professional judgment; 2) the potential that additional losses could be incurred 

while experimenting with non-lethal methods; and 3) experimenting with non-lethal approaches 

may not be appropriate in the rare instance of a wolf-related threat to human safety.

Lethal Only Program

Under this Alternative WS would only provide technical and operational assistance with lethal 

damage management techniques. In certain situations, non-lethal methods may provide shortterm or long-term solution to wolf damage problems. Prohibiting WS from using or providing 

technical assistance on effective and practical non-lethal wolf damage management methods is 

not in the best interest of the continued recovery of the species and is contrary to agency policy 

and directives (WS Directive 2.101). 

Sport Hunting and Trapping to Resolve Damages

WS has no authority to authorize or deny hunting or trapping season for wolves, nor is this 

allowable under federal ESA regulations. This issue is outside the scope of any decision that WS 

would make as a result of this EA.

Live Capture and Relocation of Depredating Wolves.

When individual wolves or wolf packs are already established as repeated depredators of 

livestock, moving them to another location may pose a high risk that the wolves would simply 

cause livestock predation losses in their new area. Wolves can and often do move long distances 

in relatively short periods of time and cannot be expected to stay in areas to which they are 

relocated. Thus, even if wolves could be relocated to remote wilderness or sparsely inhabited 

areas away from livestock, they cannot be relied upon to stay in such areas and avoid further 

livestock depredation problems. WS has no authority to authorize or require WDFW, USFWS, 

or tribes to choose this alternative, and this issue is outside the scope of any decision that WS 

would make as a result of this EA.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 40

CHAPTER 3 - ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

3.1 Issues Driving the Analysis 

The following environmental issues or resources have been evaluated in this EA to help 

determine the impacts of the proposed action on the environment and to compare the alternatives

in Chapter 4.

 Impacts on wolf populations - What might be the impact of the proposed action be on the 

growing Washington wolf population, in eastern Washington and statewide? What would be 

the cumulative effects of the proposal?

 Impacts on non-target animals and human safety - Would there be impacts on other 

species besides wolves? Could the program affect pets? Might the program have adverse or 

beneficial effects on federally protected species? Are there risks to human safety?

 Social and Aesthetic Perspectives – How acceptable are the alternatives to stakeholders? 

How is humaneness perceived? What are the implications for the aesthetic value of wolves?

 Effectiveness – A discussion on the effectiveness of the alternatives will reveal how well the 

alternative meets the purpose and need for action. This issue is not an environmental issue, 

but it is an important management consideration that will be weighed with the environmental 

findings to make an informed decision.

3.2 Issues Not Analyzed in Detail, with Rationale 

Appropriateness of preparing an EA (rather than an EIS) for a state program rather than 

preparing multiple EAs for smaller, more site-specific areas

Federal agencies have the discretion to determine the geographic scope of their NEPA analyses 

[Kleppe v. Sierra Club, 427 U.S. 390, 414 (1976)] and WS has determined that preparation of 

this EA to address wolf damage management in Washington is appropriate and consistent with 

state (Wiles et al. 2011) and federal wolf management objectives and plans. If a determination is 

made through this EA, that the proposed action would have a significant impact on the quality of 

the human environment, then an EIS may be prepared in compliance with NEPA.

Effects of wolf removal on a pack structure

Pack resilience to mortality is inherent in wolf behavioral adaptation and reproductive 

capabilities (Brainerd et al. 2008). Wolf populations have sustained human-caused mortality 

rates of 30 to 50% without experiencing declines in abundance (Keith 1983, Fuller et al. 2003). 

In addition, Brainerd et al. (2008) found that 62% of packs in recovering populations retained 

territories despite breeder loss, and of those that lost territories, one-half became re-established. 

Pup survival is primarily dependent on size of pack and age of pup because multiple pack 
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 41

members feed pups despite loss of a breeder. Pup survival in 84% of packs with breeder loss 

was similar or higher than packs without breeder loss (Mech and Boitani 2003).

WDFW, USFWS, or tribes are responsible for determining when a wolf shall be removed from a 

pack. This will occur whether WS assists with removal or not.

Ecological effects of wolf removals

Wolf removal during damage management actions, combined with other forms of mortality,

would not result in a negative effect to wolves in WA, because if WS did not remove the wolf, 

WDFW would conduct the removal or contract with a private party to conduct the removal. 

Wolf removal as a mechanism of wolf damage management is expected to support wolf 

conservation and management as discussed in the WCMPW (Wiles et al. 2011). Based on a 

review of available literature in USDA (2011a), and Mech (2012), we find no reason to expect 

that wolf removals by WS would result in significant adverse effects on the quality of the human 

environment because of possible wolf-related changes in ecosystems.

WDFW, USFWS, or tribes are responsible for determining when a wolf shall be removed from a 

pack. This will occur whether WS assists with removal or not.

Producers should consider that wolf predation losses are a cost of doing business

Livestock producers recognize that some level of predation losses are likely to occur, in spite of 

their own and government (state or federal) efforts to reduce the amount of losses. The 

WCMPW is not setting expectations of preventing all losses, nor does it prescribe lethal wolf 

damage management as a solution to all depredation incidents. The WCMPW established an 

integrated approach to resolve wolf damage complaints. In some situations, the use of non-lethal

methods alone may be adequate for resolving wolf depredation complaints, but there will be 

situations which require lethal measures. Most instances of wolf predation on sheep, for 

example, occur in spite of sheep producers’ use of herders and livestock guarding dogs to help 

protect the sheep from predation. Livestock producers incur direct losses and indirect losses

from wolves without always resulting in wolf removal. These include harassment of livestock 

by wolves, fence repairs after wolves chase livestock through fences, costs to gather and regroup

livestock dispersed by wolves, and extra costs when producers have to pay for feed because 

livestock are removed from grazing pastures to minimize risks from wolves. These and other 

indirect effects that wolves have on livestock are discussed under Section 1.2.

Tribal Lands

Tribal wildlife managers with responsibilities to protect and manage treaty-reserved wildlife 

resources in Washington may meet wolf management needs in their areas of interest and 

influence. Tribal leaders may choose how to manage wolf issues within their lands and may or 

may not coordinate with the WCMPW.

WS contacted the 29 federally recognized tribes in Washington to solicit tribal concerns for this 

EA. No issues were provided from these tribes. Because extensive outreach occurred during the 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 42

preparation of the WCMPW, no new issues arose from the outreach and consultation associated 

with this EA.

As discussed under the Proposed Action Alternative, WS determined that WS work on tribal 

lands would conform to similar depredation management protocols as allowed under the 

WCMPW and USFWS regulations. Therefore, work on tribal lands in Washington would not 

add new issues or change the analysis of effects considered in detail.

Effects on Wilderness, Wilderness Study Areas, National Parks, State Parks, and National 

Monuments

Wolf removals would not occur in National Parks or National Monuments. Because individual 

wolves may be removed from surrounding areas, the potential for a slight temporary effect on 

users of National Parks and National Monuments may occur by reducing the opportunity to view 

or hear a wolf that may have otherwise traveled into the protected area, however the effect would 

be insignificant because wolf populations would be expected to continue to grow for the reasons 

discussed in the WCMPW and in Chapter 4.

Wolf removal may occur in federally designated wilderness areas or Wilderness Study Areas. 

The Wilderness Act (16 U.S.C. §§ 1131-1136) established a national preservation system to 

protect areas “where the earth and its community life are untrammeled by man” for the United 

States. Wilderness areas are devoted to the public for recreational, scenic, scientific, educational, 

conservation, and historical use. This includes the grazing of livestock where it was established 

prior to the enactment of the law (Sept. 3, 1964). The Wilderness Act did leave management 

authority for fish and wildlife with the States for those species under their jurisdiction. Some 

portions of wilderness areas in Washington have historic grazing allotments and WS may 

conduct limited wolf removal for protecting livestock or human safety as directed by WDFW in 

accordance with the WCMPW and coordination with the Regional Forester. 

In accordance with Forest Service Manual 2323.33c, the Regional Forester may approve predator 

damage management on a case-by-case basis to protect livestock and human health and safety in 

designated wilderness. The Regional Forester will only approve the action when removing the 

offending animal would not diminish wilderness character. Any wolf control in Wilderness 

Areas would be coordinated with the Regional Forester under annual WDM work plans as 

defined in the MOU between the USFS and WS (Appendix B). Proposed WS work plans are 

reviewed by USFS during the work planning process to ensure that areas of conflict do not exist. 

Therefore, WS wolf damage management would have no negative effect on wilderness character 

or management objectives. It would not impair the wilderness designation by Congress.

WS conforms to Revisions and Clarifications to H-8550-1, Interim Management Policy for 

Lands Under Wilderness Review (March 19, 2004 memorandum (No. 2004-140) from BLM 

Director to all Washington and Field Office Officials). WS follows BLM's Interim Management 

Policy for Lands Under Wilderness Review, H-8550-1 (1995), and the MOU between BLM and 

WS.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 43

WS proposed activities on lands under wilderness review (WSAs) do not conflict with BLM 

management objectives as set forth in the RMPs. In WSAs, WS work is limited to actions 

allowed in BLM’s Interim Management Policy for Lands Under Wilderness Review (H-8550-1, 

III. G. 5., July 5, 1995), as revised (BLM 2004). These documents provide, in part, that wildlife 

damage management may be permitted in certain circumstances in order to protect domestic 

livestock and reduce human health or safety risks. Coordination is required in order that wildlife 

damage management activities planned in WSAs meet the non-impairment criteria. Proposed 

WS AWPs are presented for review by BLM during the work planning process to ensure that 

areas of conflict do not exist. If WS did not remove the wolf, as requested by WDFW or their 

agents could remove the wolf. Therefore, WS actions would have no effect on wilderness 

characteristics such as size, naturalness, solitude, aesthetics, primitive or unconfined type of 

recreation, supplemental values, and the possibility of returning the area to a natural condition as 

stated in BLM’s Wilderness Inventory Handbook from 1978 and the Interim Management Policy 

for Lands under Wilderness Review. (H-8550-1, July 5, 1995)

For the reasons discussed above, WS’ proposed wolf damage management activities would not 

negatively impact Wilderness or WSAs.

Additional issues not considered because they are outside the scope of this analysis

Issuance of permits to landowners to take wolves

Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 

federally listed are managed by the USFWS. WS’ has no authority to issue permits to 

landowners and livestock producers and this outside the scope of any decision that WS would 

make as a result of this EA. Actions by others to address wolf conflicts have been considered 

under the cumulative impacts discussions in Chapter 4.

Desire for or opposition to a hunting season for wolves

WS has no authority to authorize or deny hunting or trapping season for wolves, and this issue is 

outside the scope of any decision that WS would make as a result of this EA. 

Appropriateness of livestock grazing on public lands

Regulating or authorizing livestock grazing on public lands is the responsibility of the respective 

public land management agencies, not WS.

Appropriate population level for wolves in Washington

Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 

federally listed are managed by the USFWS. Appropriate population levels are determined by 

each agency, not WS, and this is outside the scope of any decision that WS would make as a 

result of this EA. 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 44

Other resources

The actions discussed in this EA do not involve ground disturbance or construction or alteration 

of vegetation. Therefore, the following resource values are not expected to be significantly 

affected by the alternatives analyzed: soils, geology, minerals, water quality/quantity, flood 

plains, wetlands, visual resources, air quality, prime and unique farmlands, aquatic resources, 

vegetation, cultural resources or special management areas. There are no significant irreversible 

or irretrievable commitments of resources other than a minor use of fossil fuels to operate 

vehicles. These resources will not be analyzed further.

3.3 Evaluation Methodology 

Each issue will be evaluated under each alternative and the direct, indirect, and cumulative 

effects will be disclosed as applicable. NEPA describes the elements that determine whether or 

not an impact is “significant”. Significance is dependent upon the context and intensity of the 

impact. The following factors will be used to evaluate the significance of the impacts in this EA 

that relate to context and intensity:

Magnitude of the Impact (size, number, or relative amount of impact) (intensity) –

Quantitative analysis is used where possible as it is more rigorous and is based on all known 

sources of wolf mortality and actions provided for under the WCMPW. Magnitude may be 

determined quantitatively or qualitatively;

Duration and Frequency of the Impact –

Temporary, seasonal impact, year round or ongoing (intensity);

Likelihood of the Impact –

(intensity);

Geographic Extent –

Limited to the local unit area or to the management zone (context); and

Legal Status -

Of the species that may be affected; and conformance with regulations and policies that protect 

the resource in question (context).

The analyses in Chapter 4 use the WCMPW and USFWS guidance/regulations as the 

environmental baseline under which wolves are managed. The analyses do not attempt to 

identify wolf populations or trends or whether a wolf should or should not be taken, as that is the 

responsibility of WDFW, USFWS, or tribes as the appropriate resource managers. The analyses 

are limited to what effects WS may have if WS removes a wolf compared to that of WDFW, 

USFWS, tribes, or their agents taking a wolf at the decision and request of WDFW, USFWS, or 

tribes. The cumulative effect on the gray wolf population in Washington includes past, present,

and reasonably foreseeable future actions of WS and others.
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 45

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Chapter 4 provides information needed for making informed decisions on the wolf damage 

management objectives identified in Chapter 1. This chapter uses the four issues identified in 

Section 3.1 as the evaluation criteria. Each issue will be analyzed for its environmental 

consequences under each alternative. 

Direct, indirect, and cumulative impacts are discussed in relationship to how WS’ actions under 

that alternative may affect the wolf population, non-target impacts, perspectives of human social 

values and aesthetics, and effectiveness relative to if WS did not take any action. The 

effectiveness of the alternatives is also discussed as a measure for comparison in meeting the 

purpose and need for action.

4.1 Alternative 1 – No Action 

The “No Action” Alternative is for WS to continue the existing wolf damage management 

program as is. This is the environmental status quo, a required NEPA component, a viable 

alternative that could be selected, and serves as a baseline for comparing the action alternatives 

(CFR 1502.14[d]). Under this alternative, WS would continue its current activities conducting 

investigations of livestock conflicts, providing the public with advice and recommendations on 

the appropriate use of non-lethal methods to protect livestock from wolf damage, and performing 

non-lethal control actions to reduce wolf damage.

WDFW would implement measures in the WCMPW and governing regulations and would 

remove target wolves themselves. Tribes with management authority of wolves could

implement measures according to their wildlife policies. Thus, the cumulative effects of such 

actions are the current environment under which wolves exist, and are discussed as the 

environmental baseline, or the environmental status quo.

4.1.1 Impact on wolf population 

Gray Wolf Population in Washington

As of March 2013, there were ten confirmed packs in Washington: seven packs in the Eastern 

Washington, three packs in the Northern Cascades management area, and none in the South 

Cascades & Northwest Coast management area (Figure 2). There are also indications of two 

additional packs in the Eastern Washington management area two bordering packs (one near 

Walla Walla and another in the north Cascade Mountains (Figure 2). A least a few solitary 

wolves likely occur in other scattered locations of Washington.

Continued wolf movement into Washington from adjacent states is likely given the population of 

wolves in the state of Idaho which identified 101 documented wolf packs and an estimated 

population of 746 wolves, with additional packs overlapping along bordering states (IDFG and 

Nez Perce Tribe 2012). The wolf population in Washington is expected to grow as Washington 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 46

wolves continue to reproduce and as wolves from other states and Canada enter Washington

through natural dispersal. The Idaho portion of the NRMDPS is expected to continue to supply 

new dispersing wolves to Washington, which will diversify the gene pool and fill in home ranges 

that become vacant due to lethal control, natural mortality, unintended mortalities, or westward 

dispersal. 

The rate of wolf dispersal into and throughout Washington cannot be predicted. The ability of 

wolves to reach areas of habitat outside northern and eastern Washington is assumed. There are

documented wolf packs as far west as the Cascade Mountains (Figure 2), but resident wolves or 

packs have not yet been confirmed west of the Cascade Mountains. 

As wolf activity is documented through discovery of individual wolves or wolf pack activity, 

WDFW or USFWS will continue to radio-collar and monitor individuals. By monitoring and 

observing wolves regularly, determinations regarding the habitats they select and occupy will be 

possible. Management decisions will be evaluated for reducing conflicts while promoting 

recovery.

Wolves can occupy a variety of habitats provided adequate prey is available and they are 

tolerated by humans (Wiles et al. 2011). The specific habitat chosen will be determined by prey 

availability and human tolerance and probably will include national forests, parks, and 

wilderness areas, designated roadless areas, and areas with low densities of open roads (Wiles et 

al. 2011). Areas in the Cascade Mountains, northeastern Washington, Olympic Peninsula, and 

Blue Mountains meet these criteria. 

Direct effect on the gray wolf population

WS would have no effect on individual wolves or wolf conservation and management in 

Washington under the No Action alternative, other than as a provider of technical assistance and 

select non-lethal control to WDFW and landowners. In this capacity, WS’s assistance would 

help ranchers minimize wolf damage, thereby reducing the need for some lethal removal. Lethal 

removal would still be required and conducted by WDFW and/or tribes.

Cumulative effects on the gray wolf population

WS’ actions would have no negative effects on wolf populations. The wolf population in 

Washington is expected to increase and expand throughout the state, and livestock damage is 

also expected to increase and expand (Wiles et al. 2011). WDFW wrote that if WS was not able 

to assist further, it WDFW would, by necessity, respond to wolf damage and would remove 

problem wolves as defined in the WCMPW (Appendix A). Further, WDFW indicated that it 

may remove more wolves that otherwise necessary (as compared to the Proposed Action

Alternative) since it would need to refocus its efforts away from proactive nonlethal measures. 

Ultimately, this alternative could hamper WDFW wolf recovery and conservation efforts 

(Appendix A). 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 47

4.1.2 Impacts on non-target animals and human safety 

Non-target animals

WS would have no effect on non-target animals or human safety under the No Action alternative. 

Wolf removal actions by WDFW are expected to continue. The potentially harmful non-lethal or 

lethal methods available to WS are also available to WDFW. 

WS’s use of traps and foot snares in Washington has not presented any safety risks to people

(MIS 2012). This conclusion was made on a formal risk assessment of WS methods (Appendix 

C). It is unlikely that this risk would be higher if WDFW or its agents applied these methods. 

4.1.3 Social and Aesthetic Perspectives 

Wildlife generally is regarded as a source of economic, recreational, and aesthetic benefits 

(Decker and Goff 1987), and the mere knowledge that wildlife exists is a positive benefit to 

many people. Under this alternative, WS would not take action to remove wolves and would not 

directly affect those with strong opinions on this aspect of wolf damage management or on 

humaneness, nor would WS have any positive or negative effect on the ability of the public to 

potentially experience wolves in the wild. The No Action alternative would not preclude 

WDFW and others taking actions to resolve wolf depredation, using lethal means where 

authorized.

Humaneness

Under this alternative, wolves could be trapped or shot by experienced WDFW personnel as 

humanely as possible using the best methods available. All activities would be conducted in 

accordance with Washington Administrative Codes and WDFW guidelines to minimize the 

amount of time target and non-target animals remain in traps, and improve the likelihood that a 

non-target animal may be released unharmed. WS would not lethally remove or physically harm 

any wolves including during non-lethal harassment.

Wolves could be killed by livestock producers, where they are federally delisted, under WDFW

permit or when caught in the act of attacking or killing livestock (WAC 232-36-05100B). The 

humaneness of private individuals shooting wolves would depend on the skill of the individual 

and their ability to make a quick and efficient kill. 

Some individuals would consider this alternative inhumane because they oppose all lethal 

methods of damage management. Others will be opposed to this alternative because they object 

to specific lethal wolf damage management methods like traps and cable restraints and perceive 

these methods as being unjustifiably cruel and inhumane. Some individuals would prefer that 

cage traps be used to capture wolves and would perceive this method as being more humane than 

traps and cable restraints. Unfortunately, the use of cage traps to capture wolves is impractical 

and ineffective because it is extremely difficult to get a cage trap big enough for an adult wolf 

into remote locations, and because it is rare to capture an adult wolf in a cage trap (USDA 2006). 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 48

Individuals with animals that have been injured, threatened, or killed by wolves may see this 

alternative as being acceptable because it includes necessary lethal actions to help prevent further 

injuries to their livestock and pets.

Finally, livestock owners feel that they have a right to protect their property, and may consider it 

unacceptable that their domesticated animals be subjected to harm by wolves. 

Aesthetic Effects 

Aesthetics is the philosophy dealing with the nature of beauty, or the appreciation of beauty. 

Therefore, aesthetics is truly subjective, dependent on what an observer regards as beautiful. 

Direct benefits are derived from a user’s personal relationship or direct contact with wildlife and 

may include either consumptive (e.g., using or intending to use the animal such as in hunting or 

fishing) or non-consumptive use (e.g., observing or photographing animals) (Decker and Goff 

1987). Indirect benefits, or indirect exercised values, arise without a human being in direct 

contact with an animal and are derived from experiences such as looking at pictures or videos of 

wildlife, reading about wildlife, or benefiting from activities or contributions of animals such as 

their use in research (Decker and Goff 1987). Two forms of indirect benefits exist according to 

Decker and Goff (1987): bequest and pure existence. Bequest benefits arise from the belief that 

wildlife should exist for future generations to enjoy; pure existence benefits accrue from the 

knowledge that the animals exist in the human environment (Decker and Goff 1987) or that they 

contribute to the stability of natural ecosystems (Bishop 1987). 

Some people directly affected by problems caused by wolves insist on the lethal removal of the 

problem animal(s) from the area where the conflict occurs. Others have the view that all wildlife 

involved in conflicts should be captured and relocated to another area to alleviate the problem. 

Individuals not directly affected by a conflict may be supportive of affected humans, neutral, or 

totally opposed to any removal of wildlife from specific locations or sites. 

Those who oppose removal of wildlife may do so because of emotional or spiritual ties to the 

animals, which are similar to the bonds that may exist between a human and a pet. Some may 

totally oppose wolf damage management, especially if lethal methods are used, and want 

management agencies to teach tolerance of wolves causing conflicts. These individuals generally 

believe that individual animals have inherent value and should not be killed to meet the desires 

of man-kind. They may also feel that individual animals have rights similar to those of humans 

and that, if it is inappropriate to treat a human in a given manner, then it is also inappropriate to 

treat an animal in that manner. 

Under this alternative WS would not remove wolves. WDFW would still remove problem 

wolves (Appendix A), as could tribal authorities. The ability to view and aesthetically enjoy 

wolves at a particular site could be temporarily limited when the wolves are removed. New 

animals would most likely reoccupy the site in the future if suitable habitat exists, although the 

length of time until new wolves arrive is variable, depending on the habitat type, time of year, 

and population density of wolves in nearby areas. An objective of the WCMPW is to conserve 

wolves to the point of recovery, while managing conflicts. Given that wolves are expected to 

continue to expand in number and range in Washington, the current program alternative and 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 49

environmental status quo will not jeopardize the viability of the wolf population, thus 

opportunities to view, hear, and aesthetically enjoy wolves will likely be available to the public 

and grow over time as wolves reach recovery and management stages. 

4.1.4 Effectiveness 

The integrated and adaptive approach employed by WDFW, USFWS, or tribes under the 

WCMPW could incorporate the use of lethal and non-lethal measures to stop or reduce the 

likelihood of wolf damage. In assessing the effectiveness of various management approaches to 

dealing with wolf predation on livestock in the NRM area, Bangs et al. (2009) concluded that 

while non-lethal tools were temporarily helpful in some situations, they were generally 

ineffective, particularly in areas that simply would have too many livestock conflicts for wolf 

packs to persist. That is, scaring wolves away from one specific location in an area with large 

numbers of livestock everywhere else simply results in the wolf conflicts with livestock in 

adjacent areas where focused non-lethal efforts are not being employed or as ardently. Bangs et 

al. (2009) also concluded that lethal management of problem wolves was usually effective in 

reducing conflict because it: 1) enhanced effectiveness of non-lethal control measures, 2) 

interrupted use of livestock as food by surviving wolves, 3) removed offending individuals, 4) 

reduced wolf density in conflict areas, 5) eliminated packs where repeated livestock depredations 

had been occurring, 6) helped to keep wolf packs out of unsuitable habitat, 7) made surviving 

pack members temporarily avoid or be more wary of people and/or areas with livestock, 8) 

reduced the pack’s overall need for food, 9) made it more difficult for the fewer remaining pack 

members to kill larger prey like adult cattle or attack calves protected by cows, 10) increased the 

detection rate of subsequent depredations because livestock carcasses were consumed more 

slowly (so additional control could be applied more rapidly), 11) reduced compensation and 

control costs, and 12) moderated some of the public anger over wolf predation on livestock. 

Mech (1995) similarly concluded that in most circumstances, lethal removal of wolves was 

usually the only practical approach to resolving incidents of wolf predation on livestock. 

Karlsson and Johansson (2009) reviewed data on livestock predation by brown bears, wolves and 

lynx on farms in Sweden and concluded that the risk of predation greatly increased during the 

first several weeks after an initial predation incident. They suggested that control efforts, 

whether lethal or non-lethal, would be most effective if applied during this period of time 

following an initial depredation event. Bradley (2004) found that after partial or complete wolf 

pack removal, depredations usually ceased for the remainder of the given grazing season. 

However, the majority of packs that were partially removed (68%) depredated again within the 

year. Where entire packs were removed, the rate of re-colonization was high (70%) and most recolonization (86%) occurred within a year of removal of the previous pack; most packs (86%) 

that recolonized the same area were implicated in depredations. Packs in which breeders were 

removed were no less likely to cause depredations again within the year than packs with nonbreeders removed. 

Although non-lethal methods are often only temporarily effective, they may sometimes offer 

protection for a long enough period of time to protect a resource when it may be most vulnerable. 

An example is the use of the RAG box in small calving pastures. Breck et al. (2002) reported 

that this frightening device, activated by the radio signal from an approaching radio-collared 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 50

wolf, was effective in keeping a radio-collared wolf pack away from several small calving 

pastures in central Idaho for 60 days. However, this device is only useful in those cases where at 

least one and preferably multiple wolves in the pack are radio-collared, and it is only useful for 

protecting relatively small areas. Fladry has also been used to deter wolves for up to 60 days 

before the wolves habituated to it and began killing livestock again (Musiani et al. 2003). One 

consideration in the use of these temporarily effective non-lethal methods, is, that if wolves will 

eventually be lethally removed anyway (after habituating to the frightening stimulus), the 

investment of time and resources in the non-lethal efforts may not be practical. 

One of the most effective non-lethal deterrents to wolf predation may be the on-site presence of 

humans who remain near the livestock and are vigilant in trying to detect the presence of wolves 

so they can be consistently frightened away (Shivik 2004). These efforts can be more effective if 

there are radio-collared wolves in the area and the livestock guardian personnel make use of 

radio-telemetry receivers to detect the nearby presence of wolves. The costs to provide 24/7 

human presence around livestock would ordinarily be cost-prohibitive for livestock producers, 

but in some situations, outside parties with an interest in wolf conservation have provided such 

assistance at no cost to livestock producers, in order to promote greater tolerance for wolves. 

The Defenders of Wildlife have paid for such efforts in the Big Wood River drainage of central 

Idaho during several recent summer grazing seasons, and while these efforts have not been 100% 

effective in eliminating wolf problems, they appear to have been effective in reducing the 

number of wolf attacks on sheep and livestock guarding dogs in this area (USDA 2010). 

Bangs and Shivik (2001) reported that while some non-lethal methods may be temporarily 

effective, many are expensive to implement and none available at the time of their report were 

widely effective. Many non-lethal methods of preventing livestock losses to wolves have been 

tried and abandoned in the United States and Europe because of lack of effectiveness. Use of 

guard dogs alone has been tried against wolves in Minnesota with only limited success (Fritts et 

al. 1992). Coppinger and Coppinger (1996) showed the dominance of wolves over livestock 

guarding dogs in direct confrontations, and Coppinger and Coppinger (1996) and Bangs et al. 

(1998) reported that wolves have killed livestock guarding dogs. Wolves have also been 

translocated to other areas, but many either returned to where they were caught or became a 

problem elsewhere (Fritts et al. 1984, 1985). Mech et al. (1996) concluded that where wolf 

populations are large and secure, translocation has little value in wolf management. Aversive 

conditioning (Gustavson and Nicolaus 1987, Shivik and Martin 2001, Shivik et al. 2003) has not 

yet proven effective with wild wolves (Fritts et al. 1992). Electric fencing may hold some 

promise for protecting livestock from wolves, but fences tested for coyotes have been extremely 

expensive, high maintenance, and better suited for small areas (Dorrance and Bourne 1980, Nass 

and Theade 1988, Paul and Gipson 1994), rather than range operations. 

In looking at the possible role of livestock husbandry practices in reducing wolf predation, 

Bradley and Pletscher (2005) assessed multiple factors potentially related to wolf depredations 

on cattle in fenced pastures in Montana and Idaho. They concluded there was no relationship 

between depredations and carcass disposal methods, calving locations, calving times, breed of 

cattle, or the distance cattle were grazed from the forest edge. They did find that depredations 

were more prevalent in pastures where elk were more likely to occur, where the pastures were 

larger in size, had more cattle, and where cattle were grazed farther from residences than 
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 51

pastures without depredations. Mech et al. (2000) likewise concluded there were essentially no 

differences in husbandry practices between farms in Minnesota that suffered repeated wolf 

depredations, as compared to similar operations which experienced no depredations, and that 

farms with cattle farther from human habitation suffered more losses. 

Haight et al. (2002) and Cochrane et al. (2003) reported on a model developed to assess three

different strategies for reducing wolf predation on livestock, including: 1) reactive management, 

where wolf removal occurred soon after depredations occurred, 2) delayed reactive management, 

where wolf removal occurred in the winter months prior to the grazing season in areas with a 

history of previous depredations, and 3) population-size management, where wolves were 

removed annually in the winter months from all areas near farms. The authors’ concluded that: 

1) each of these approaches reduced predation by about half compared with no action, 2) delayed 

reactive management and population-size management actually removed fewer wolves than 

reactive management because wolves were removed in winter before pups were born, and 3) 

population-size management was least expensive because repeated annual removal kept most 

territories near farms free of wolves. The WCMPW allows lethal methods to only be used as a 

reactive approach. 

In conclusion, non-lethal methods are used and recommended but not always successful in 

stopping or reducing damages, especially over time and must be supplemented with lethal 

methods. WDFW’s approach is to allow for limited lethal removal of wolves after they have 

been confirmed to have been involved in repeated livestock depredation. WDFW has indicated 

that it would target wolves for lethal control, similar to the Proposed Action Alternative, 

however without additional assistance from WS, service to landowners may be reduced or 

delayed and WDFW would have to redirect their personnel from conservation and recovery 

focus to lethal removal, thus wolf depredation on livestock may increase and overall 

conservation and recovery may be slowed. 

4.2 - Alternative 2 – Eliminate the Current Wolf Assistance Program

Under Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 

not provide any wolf assistance to WDFW, other public agencies, or private individuals within 

Washington. WS would not distribute available equipment or assist landowners with the 

implementation and use of non-lethal methods and devices. WS would not investigate wolf 

depredation complaints to determine if the wolves are responsible for losses. WDFW, USFWS, 

and tribes could take the same actions as those described under the No Action alternative, thus 

nonlethal and lethal control would still occur. The cumulative effects of such actions are similar 

to the current environment under which wolves exist, and are discussed as the environmental 

baseline, or the environmental status quo in Section 4.1.
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 52

4.2.1 Impact on wolf population 

Direct effect

WS would have no involvement or effect with/on wolves. 

Cumulative effects on gray wolves in Washington

The cumulative effects on wolves would be similar to that described under Section 4.1.1. 

USFWS has responsibility for managing federally listed wolves, WDFW has responsibility for 

managing federally delisted wolves, and tribal governments have authority on tribal lands within 

their boundary. Ranchers and livestock producers must work directly with WDFW and USFWS

when wolf/livestock conflicts occur in their areas of management. Livestock producers that see 

wolves on their property or suspect wolves have attacked livestock are instructed to immediately 

call WDFW, USFWS, or county officials. WDFW, USFWS, or tribes would implement wolf 

damage management per appropriate regulations, as discussed in Section 2.1, and individual 

wolves are expected to be removed when and where a need exists and in accord with the 

requirements for removal. In addition, producers in areas where wolves are managed by the state 

(currently within the NRMDPS boundary), and who have been issued a WDFW permit or catch 

wolves attacking their animals (WAC 232-36-05100B), may kill wolves. 

Because WDFW would implement the WCMPW with or without the assistance of WS

(Appendix A), effects on the wolf population would be similar to the No Action Alternative.

4.2.2 Impacts on non-target animals and human safety 

Non-target animals

WS would have no effect on non-target species or humans under this alternative. 

Human Safety

WS would have no effect on human safety under this alternative.

Cumulative effects in Washington

Lethal methods would be used by WDFW, its agents, or tribes in the absence of any assistance 

from WS, and thus would present no change in human safety risk from that of the current 

environmental baseline (the No Action alternative). 

In the unlikely event that wolves threatened human safety, WDFW, USFWS, and tribes could 

take actions as allowed under the WCMPW, ESA, CFR, or tribal guidance. 
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 53

4.2.3 Social and Aesthetic Perspectives 

Non-lethal actions are generally preferred by members of the public. However, members of the 

public who experience wolf threats to or losses of livestock, as well as some pet owners, feel that 

they have a right to protect their property, and may consider it unacceptable that their 

domesticated animals be subjected to harm by wolves by using non-lethal methods if they are not 

effective. People have bred the defensive capabilities out of many domestic animals and thus 

may feel that they have an obligation to protect them from being killed by predators. 

As discussed in Section 4.1.3, livestock producers, some rural residents, and hunters would be 

more likely to approve of the most effective methods that will reduce wolf damages, and some 

members of the public would prefer if wolves were removed from Washington. 

Because WDFW (Appendix A), USFWS, or tribes could take necessary action to lethally remove 

wolves under this alternative, ultimately, social perspectives would be expected to be similar to 

the No Action Alternative.

Humaneness

The effects of this alternative would be similar to the No Action alternative because of the role of 

WDFW in implementation of the WCMPW, which allows for nonlethal and lethal control. 

Impact of wolf removal on public aesthetic enjoyment

Under this alternative, WS would have no effect on the ability of the public to enjoy wolves 

since it would have no effect on individual wolves or the wolf population. However for the 

reasons discussed under the No Action alternative, WDFW, USFWS, or tribes could take any 

necessary lethal actions and wolves would be affected similar to the No Action alternative. 

Thus, the ability of the public to potentially enjoy wolves in their natural habitat would be the 

same as Alternative 1, No Action.

4.2.4 Effectiveness 

Eliminating all assistance from WS would necessitate WDFW, USFWS, or tribes to direct 

personnel away from proactive damage management and conservation and recovery efforts, 

which would likely negatively affect wolf conservation and recovery and may result in increased 

wolf depredation on livestock (Appendix A). 

4.3 Alternative 3 – Proposed Action Alternative: Expand the Current Wolf Assistance 

Program

The Proposed Action Alternative is to assist livestock producers, tribes, WDFW, and USFWS

with an integrated approach of technical assistance, wolf damage identification, and nonlethal

and, with the exception of USFWS, lethal wolf damage management approaches under the 

WCMPW or similar guidance. WDFW, USFWS, and tribes would continue to implement 

aspects of relevant wolf management (e.g., recovery and conservation) and WS would cooperate 

to provide the assistance necessary to respond to wolf complaints and resolve depredation. This 
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 54

alternative is almost identical to the No Action alternative except that WS could respond to 

WDFW or tribe requests to provide conservation trapping and lethal removal in accordance with 

the WCMPW or similar guidance and assist the USFWS with conservation trapping when 

requested and under ESA guidelines. Having WS assist WDFW or the tribes with lethal removal 

of wolves will allow the other agencies to focus their personnel towards conservation and 

recovery of wolves in Washington.

This alternative is an improvement over the No Action alternative with actions allowed under the 

WCMPW, and the environmental consequences are similar to those under Alternative 1, No 

Action, because WS would be involved with lethal and non-lethal wolf damage management, 

instead of only WDFW, USFWS, or tribal personnel. The environmental consequences would 

be fewer than Alternative 2 as well, because WDFW would not be required to redirect its 

personnel from conducting wolf conservation and recovery projects. This alternative is expected 

to have the greatest efficacy in reducing wolf damage while benefiting wolf conservation and 

recovery in WA.

4.3.1 Impact on wolf population 

Direct effect

Effects on the wolf population under this alternative could result in a similar or lower level of 

wolf removal as compared with Alternatives One and Two (Appendix A). Under this alternative, 

WS may respond to WDFW or tribal requests to remove individual problem wolves under the 

conditions of the WCMPW or similar guidance and assist USFWS with wolf conservation efforts 

under ESA guidelines. This alternative would allow WDFW, USFWS, and tribal personnel to 

focus their efforts on conservation and recovery of gray wolves in Washington. It would not 

result in more wolves removed since WDFW, USFWS, or tribes are responsible for determining 

the number of wolves to remove and would respond if WS could not (Appendix A). 

Cumulative effects on gray wolves in Washington

The cumulative effect on the gray wolf population in Washington would be similar or lower than 

Alternatives One and Two. WDFW is already implementing the WCMPW and would continue 

to respond to wolf damage complaints in the absence of WS assistance (Appendix A). Without 

WS assistance, WDFW may need to take more wolves to address wolf damage (Appendix A). 

Because WDFW or tribes must make the decision regarding individual wolf removals of wolves 

under their jurisdiction, and because WS would be bound to the measures discussed in the 

WCMPW (Wiles et al. 2011) or similar guidance, the discussion and findings under the No 

Action Alternative, in which WDFW, USFWS, and tribes would act if WS did not, is expected to

be similar.

Under this alternative, WS would provide assistance to WDFW or tribes with lethal and nonlethal wolf damage management and USFWS with non-lethal management and lethal 

management under provisions of the ESA. By providing WDFW and tribes with lethal 

management assistance, WDFW and tribes would be able to focus their personnel towards 

programs to enhance wolf recovery and conservation. Therefore, when compared with the No 
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 55

Action (current program) and Eliminate the Wolf Assistance Program alternatives, the Proposed 

Action Alternative would result in the greatest overall potential for wolf conservation by 

allowing WDFW (Appendix A), USFWS, and tribes to focus their staff time on wolf 

conservation and recovery efforts.

Ultimately, based on WS assistance to USFWS, WDFW under the WCMPW, WDFW’s public 

education and outreach, and the cautious and conservative approach to reducing wolf 

depredation, wolves are expected to continue to expand in Washington and establish populations 

in suitable habitat. Based on habitat connectivity and an abundance of wolves in other regions of 

the NRMDPS, it is reasonable to expect that wolves will expand within the foreseeable future to 

meet state and federal delisting criteria in Washington.

The Colville Indian Tribe opened wolf hunting to its members through 28 February 2013 or until 

3 wolves are taken in each of the 3 assigned regions on the Colville Indian Reservation. This 

action was taken after communication with state authorities and done in order to control wolf 

populations that threaten the deer and elk tribal members rely on. WDFW takes tribal hunting 

into account when determining wolf recovery actions so that tribal hunting will not add adverse 

cumulative impacts to WDFW permitted wolf removals during wolf conservation and recovery 

processes. WDFW does not believe that this action will inhibit wolf recovery efforts in 

Washington (Pers. comm. Dave Ware, WDFW, July 2013).

Because Washington wolf conservation and management is a relatively new issue, WS has 

limited its proposed role in using lethal depredation management methods to the guidance under 

the WCMPW, ESA, or similar guidance from tribes.

4.3.2 Impacts on non-target animals and human safety 

Non-target animals

There would be little to no difference in the effect to non-target animals because WDFW, its 

agents, USFWS, WS, and tribes could use the same tools. Neck snares have potential to affect 

non-targets. The exposure of non-target animals to neck snares is mitigated through consultation 

with the USFWS under Section 7 of the ESA. Neck snares would primarily be used in the winter 

time when few non-target species are present, set in wolf trails leading to/away from depredation 

sites, and set to avoid capturing non-target animals. While there may be some risk to larger nontarget animals such as bear and cougar, the level of use of lethal tools would be so low as to 

render negative effects on non-target species unlikely. WS may apply other techniques more 

proficiently than WDFW, so effects to non-targets could be somewhat less under this alternative. 

WS may use neck snares when foothold traps are less effective due to their mechanical nature. 

This tool is available to WDFW, and WS as its agent, under RCW 77.15.010, so it may not result 

in a difference in removing depredating wolves to promote wolf recovery and conservation in 

WA.

WS Standard Operating Procedures to minimize the capture of non-target animals is discussed in 

Section 2.3.
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 56

Threatened and Endangered Species

During development of this EA, Wildlife Services reinitiated a programmatic (state-wide, all 

WS’ actions) consultation with the USFWS (February 1, 2013), pursuant to the federal 

Endangered Species Act, for potential program effects on bull trout (Salvelinus confluentus), 

Canada lynx (Lynx canadensis), Columbian white-tailed deer (Odocoileus virginianus leucurus), 

gray wolf (Canis lupus), grizzly bear (Ursus arctos horribilis), pygmy rabbit (Brachylagus 

idahoensis), and Pacific coast population of the western snowy plover (Charadrius nivosus 

nivosus). On November 21, 2013, WS included ESA consultation/conferencing involving 

streaked horned lark (Eremophila alpestris strigata) and wolverine (Gulo gulo). 

During discussions subsequent to the February 1, 2013 consultation with USFWS, WS agreed 

that certain actions may adversely affect grizzly bear if WS accidently captured a grizzly bear 

during wolf trapping actions. Therefore USFWS included an analysis of potential adverse 

effects to grizzly bear. In order to ensure that WS actions would not jeopardize federally grizzly 

bear or gray wolves, WS would implement the conservation measures proposed in Section 2.3 of 

this EA. 

On July 21, 2014, USFWS provided their Biological Opinion to WS programmatic Section 7 

consultation. USFWS determined that WS’ actions from the proposed program (i.e., statewide, 

including the proposed action alternative evaluated in this EA) are not likely to jeopardize the 

continued existence of Threatened or Endangered Species in Washington (Table 2). USFWS 

issued WS incidental take statements for up to 33 federally listed gray wolves and 1 grizzly bear 

over the 10-year consultation period.

Table 2. Breakdown of WS' and USFWS' determinations of affects from WS' proposed actions in WA.

Species WS' Determination USFWS's Determination Expected Outcome of WS' Proposed Program

Bull trout NLAA Concurred Not likely to jeopardize the continued existence of

Canada lynx NLAA Concurred Not likely to jeopardize the continued existence of

Columbian white-tailed deer NLAA Concurred Not likely to jeopardize the continued existence of

Gray wolf LAA Concurred Not likely to jeopardize the continued existence of

Green sea turtle N E

Grizzly bear NLAA LAA Not likely to jeopardize the continued existence of

Leatherback sea turtle N E

Loggerhead sea turtle N E

Marbled murrelet N E

Mazama pocket gopher N E

Northern spotted owl N E

Olive ridley sea turtle N E

Pygmy rabbit NLAA Concurred Not likely to jeopardize the continued existence of

Short-tailed albatross N E

Streaked horned lark LAA Concurred Not likely to jeopardize the continued existence of

Taylor's Checkerspot N E

Western snowy plover LAA Concurred Not likely to jeopardize the continued existence of

Woodland Caribou N E

Wolverine Not listed, but WS does 

not anticipate jeopardizing Found Reasonable Not likely to jeopardize the continued existence of

NLAA = Not Likely to Adversely Effect, LAA = Likely to Adversely Effect, NE = No Effect (NE does not require USFWS consultation)
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 57

Human Safety

The methods proposed by WS would be the same as those used by WDFW under the No Action 

alternative. WS is unaware of any impacts to public health or safety associated with agency 

implementation of wolf damage management methods in other states. 

Aerial operations would likely occur in relatively remote areas with no or very low human 

presence on the ground. A formal risk assessment of methods used in wildlife damage 

management concluded there was very little, if any, risk to the public from WS aerial shooting 

activities (Appendix C). Other analyses of aircraft accidents by WS concluded that the accident 

rate for WS pilots and aircraft is not significantly different from rates reported for general 

aviation and that the risk of harming any member of the public is exceedingly low (USDA 

2011a, 2011b). We find no reason to believe that aerial operations used in wolf damage 

management would present any significant risk to public health or safety in Washington.

WS’ traps and snares are strategically placed to reduce the likelihood of exposure to the public. 

Appropriate warning signs are posted at access points to areas or properties where traps or snares 

are set to alert the public of their presence (WS Directive 2.450). In Idaho, where wolf removal 

efforts are relatively high compared to what is anticipated in Washington, there have been no 

injuries from WS wolf damage management activities reported to WS, USFWS, Idaho Fish and 

Game.

Humans are not likely to be exposed because of the remoteness or locations on private lands 

where wolf removals generally occur. WS’s use of traps and snares has not presented any safety 

risks to people (MIS 2012). This conclusion was made on a formal risk assessment of WS 

methods (Appendix C). Similar to the No action alternative, this Alternative could provide relief 

from damage or threats to public health and safety for people who would have no relief from 

such damage or threats if non-lethal methods were ineffective or impractical. 

4.3.3 Social and Aesthetic Perspectives 

Humaneness

People’s perspectives on wolf damage management and on the removal of wolves under the 

Proposed Action Alternative would be expected to be similar to the No Action and Non-lethal 

only alternatives since wolves would be removed in a similar manner and number, under the 

same criteria (Wiles et al. 2011), and for the same reasons. While WS may act as an agent to 

landowners holding lethal removal permits, additional take is unlikely for the reasons discussed 

under Section 4.3.1. 

With regard to the humane treatment of wolves, the proposed action would be similar to the 

other alternatives as far as lethal methods that WS would use (as discussed in Section 4.1.3). WS 

would continue to provide non-lethal technical assistance to all who request it. The overall 

humaneness of the wolf management program may be enhanced under the Proposed Action

Alternative because by assisting WDFW and tribes with lethal depredation response efforts, they 

can focus their personnel towards recovery and conservations actions. 
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 58

With regard to the perspective of livestock producers and others who feel that domestic animals 

should be protected from predation, this alternative would probably be considered more humane 

than the other alternatives because WS may be able to respond to WDFW, USFWS (under ESA 

guidelines), and tribal requests for lethal removal faster and more efficiently than their agents 

could. WS already has personnel in the field that have the expertise to identify and resolve 

wildlife damage. By expediting response times, the potential for continued or additional wolf 

depredation on livestock can be reduced. Enhancing agency depredation management efficiency 

is likely to promote social tolerance of wolves in Washington, as discussed under Section 4.1.3. 

Aesthetic effects

Some individuals contend that there is an “existence value” placed on wolves: that a value exists 

even though a large segment of the public will never actually see or hear a wolf. Because WS is 

not proposing to remove all wolves nor would WDFW authorize the killing of all wolves as a 

manner to recover and conserve the species in Washington, there will be wolves available to 

continue the concept of “existence value”. The ability to view and aesthetically enjoy wolves at 

a particular site could be temporarily limited when a wolf is removed. New animals would most 

likely reoccupy the site in the future if suitable habitat exists, although the length of time until 

new wolves arrive is variable, depending on the habitat type, time of year, and population density 

of wolves in nearby areas. While non-consumptive users could be temporarily affected by 

localized removals (especially if they recreated in areas where wolf/livestock conflicts were 

occurring), the overall effect would be beneficial in terms of the potential for people to 

aesthetically enjoy wolves in the wild in the long term. This alternative would provide the 

highest level of support towards wolf conservation and recovery in Washington as identified in 

the WMCPW (Wiles et al. 2011, Appendix A). Therefore, non-consumptive users would benefit 

most from this alternative. Still, there are likely to be groups and individuals who would be 

opposed to any control of wolves, regardless of the long-term beneficial role it plays in the 

conservation of wolves.

The likelihood of getting to see wolves is probably very low currently due to the limited numbers 

of wolves in Washington, the remote areas they inhabit, and the lack of access to private lands 

where wolves often occur. The ability to directly enjoy wolves in the wild will probably be 

greatest for people who have knowledge of wolf behavior and habits and make the effort to visit 

sites with adequate habitat outside of damage management areas. 

4.3.4 Effectiveness 

The effectiveness of the tools and techniques proposed under this alternative to manage 

depredation would be similar to the No Action alternative since either way, non-lethal methods 

are in use when they are effective, and agency lethal control would take place using the same 

approach as provided by WCMPW. However, the Proposed Action Alternative would likely be 

more efficient in resolving depredation than the No Action and Eliminate the Wolf Assistance 

Program alternatives in alleviating additional livestock damages. WS may be more efficient in 

responding to agency or tribal orders to remove depredating wolves as prescribed and needed to 

prevent further losses because it has personnel in the field who already assist landowners with 

other wildlife damage conflicts. WS personnel may be more readily available to provide 
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 59

assistance sooner than if WDFW or tribes alone implemented lethal measures on depredating 

wolves. As WDFW stated on 11 January 2013, in a letter to WS (Appendix A), 

We anticipate continued rapid growth of Washington’s wolf population and 

without your help, we will not be able to adequately address or manage conflicts. 

If we are unable to adequately manage conflicts, public tolerance for wolves will 

decline and recovery efforts could be jeopardized. While WDFW would still 

provide necessary removals of wolves in the absence of additional WS assistance, 

WDFW will not be able to respond as efficiently to potential or actual 

depredation events and thus producers may suffer greater levels of damages. 

Additionally, without your program’s expert assistance, WDFW would probably 

need to redirect personnel from overall conservation and recovery to focus on 

responding to damages. For these reasons, without the assistance of your 

program, overall conservation and recover y may be hampered.

The same number or fewer wolves may be removed under this alternative (Appendix A), and

targeting and capture of depredating wolves would be expedited under the Proposed Action

Alternative. Because repeatedly depredating wolves may continue depredating on livestock, 

fewer livestock losses would probably occur under this alternative. Removing a depredating 

wolf early may also result in fewer pack members learning to depredate livestock, thereby 

reducing future depredations further.

4.4 Summary and Conclusions 

This EA discusses approaches that WS could take to respond to requests from WDFW, USFWS, 

and tribes to assist with implementing portions of the WCMPW (Wiles et al. 2011) or similar 

guidance. The essential decision presented to WS, is not how to manage wolf damage to 

livestock, but whether or not to assist the WDFW, USFWS, and tribes with specific actions 

dictated by the WCMPW or similar guidance. This EA also evaluates the current non-lethal only 

alternative (No Action). The analysis in the EA shows that results of the No Action and 

Eliminate the Wolf Assistance Program alternatives would be similar to the Proposed Action

Alternative because WDFW and tribes would continue to take necessary actions to remove 

repeatedly depredating/problem wolves if WS did not. The primary differences between the 

alternatives are the probable increased efficacy of the Proposed Action in reducing livestock 

damage and enhancing the ability of WDFW and the USFWS to conserve wolves to the point of 

recovery, as compared with the No Action and Eliminate the Wolf Assistance Program 

alternatives. WS has no decision authority over WDFW, USFWS, or tribes in regards to calling 

for the removal of problem wolves. The decision to be made is to respond or not respond to their 

requests directing when, where, and which wolves should be removed. The methods used to 

capture wolves include the same methods described in Chapter 2 which WS would use in 

providing requested assistance. The WCMPW is very specific about the criteria which call for 

any lethal effects on wolves and if WS were to participate, it would be following such direction 

by WDFW or similar direction from USFWS (under ESA guidelines) or tribes (under their 

sovereign tribal authority). 
CHAPTER 5. LITERATURE CITED

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 60

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Washington Department of Fish and Wildlife, Olympia, Washington. 215 pp.

Wiles, G. J., H. L. Allen, and G. E. Hayes. 2011. Wolf conservation and management plan for 

Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 297 pp.

.
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Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 67

Appendix A: WDFW Letter

RECEIVED

JAN 14 ·2013-=

State of Washington

Department of Fish and Wildlife

BY:

Mailing Address: 600 Capitol Way N, Olympia,WA 98501-1091,(360) 902-2200,TDD (360) 902-2207

Main Office Location:Natural Resources Building,1111 Washington Street SE, Olympia,WA

January 11, 2013

Roger Woodruff

State Director

Wildlife Services for Washington and Alaska

USDA Anima l and Plant Health Inspection Service

720 O'Leary Street Northwest

Olympia, Washington 98502

Dear Mr. Woodruff:

Thank you for your recent letter and follow up questions requesting information and clarification 

regarding the Washington Department of Fish and Wildlife's (WDFW) implementation of 

Washington's Wolf Conservation and Management Plan (Plan). The Plan was adopted by the 

Washington Fish and Wildlife Commission in December 2011 and implementation began

immediately. WDFW has been somewhat surprised by how quickly Washington's wolf population

has increased and the level of conflicts experienced over the past several months.

We are requesting the assistance of Wildlife Services (WS) in helping us address wolf conflicts and

in capture and monitoring efforts for management and research as part of implementing the Plan. 

We request WS's participation in these activities anywhere in the state where WDFW is the lead. 

We also ask that WS assist us were the U.S. Fish and Wildlife Service has management authority

through the Endangered Species Act, but has authorized WDFW to take management actions.

WDFW has been trapping, capturing, and monitoring wolves since 2008, and we currently have 

eight confirmed packs and four suspected packs being monitored by the Department and/or 

cooperating tribes. Wolves were killed by WDFW this year for the first time in response to 

chronic depredation of livestock. Our efforts to kill wolves included trapping and shooting, both 

from the ground and with the aid of a helicopter. These lethal removal efforts will continue by

WDFW regardless of whether WS is able to assist us. WDFW is authorized and plans to implement 

a variety of wolf-livestock management measures including: preventative advice, deterrents,

harassment, and lethal removal in cases of chronic depredation. Lethal removal authority for

WDFW includes using foothold traps, shooting (including aerial techniques), and snares.
APPENDIX A

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 68

Roger Woodruff

January 11, 201 3

Page 2

We are requesting WS assistance with wolf-livestock conflict management because we do not 

have the capacity to adequately address the level of conflict we have already experienced. We 

anticipate continued rapid growth of Washington’s wolf population and without your help,

we will not be able to adequately address or manage conflicts. If we are unable to adequately

manage conflicts, public tolerance for wolves will decline and recovery efforts could be

jeopardized. While WDFW would still provide necessary removals of wolves in the absence

of additional WS assistance, WDFW will not be able to respond as efficiently to potential or

actual depredation events and thus producers may suffer greater levels of damages. 

Additionally, without your program’s expert assistance, WDFW would probably need to

redirect personnel from overall conservation and recovery to focus on responding to damages. 

For these reasons, without the assistance of your program, overall conservation and recover y

may be hampered.

One of the lessons we learned this year is the need to anticipate conflicts rather than just

respond to reported depredations. We want to be working with livestock producers proactively

next spring and using techniques to minimize conflicts rather than responding to escalating

depredation events. This proactive approach should help us minimize the number of lethal

removals necessary and hopefully completely avoid the need for the removal of an entire pack.

WDFW staffing levels and resources are not adequate for such a comprehensive proactive

approach, even at current wolf population levels. This shortfall will become even worse with the 

anticipated growth of Washington’s wolf population during the coming year.

We are look forward to working with WS in completing the environmental assessment and

in implementing Washington’s Wolf Conservation and Management Plan. We feel these are 

important steps for recovery of sustainable wolf populations in this state.

Sincerely,

Nate Pamplin, Assistant Director

Wildlife Program
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 69

Appendix B: 2011 MOU between WS and USFS

MEMORANDUM OF

UNDERSTANDING Between

USDA ANIMAL AND PLANT HEALTH INSPECTION SERVICE-WILDIFE

SERVICES

And The

USDA, FOREST SERVICE

NATIONAL FOREST SYSTEM

This MEMORANDUM OF UNDERSTANDING is hereby made and entered into by and

between USDA, Animal and Plant Health Inspection Service-Wildlife Services, hereinafter

referred to as·“APHIS-WS”,·and the USDA. Forest Service, National Forest System,

hereinafter referred to as the “U.S. Forest Service."

Background: The APHIS-WS and the Forest Service are agencies of the United States

Department of Agriculture (USDA) concerned with wildlife damage management

(WDM) and research on National Forest System (NFS) lands.

For the purposes of this agreement, WDM refers to actions initiated by APHIS-WS to

manage indigenous and feral vertebrates causing resource damage on NFS lands, to

minimize livestock losses due to predation by coyotes, mountain lions and other

predators, to manage wildlife diseases, to manage invasive species like feral hogs, and to

protect other wildlife, plants, and habitat from damage as requested by the Forest Service

and/or State or Federal wildlife management agencies. Under the Multiple Use

Sustained-Yield Act of 1960 (16 U.S.C. 528-532) and other authorities, the Forest

Service conducts activities to control wildlife damage to NFS resources caused by small

mammals and other animals, such as damage to timber stands by beavers. Occasionally,

WDM actions may be taken on NFS lands to protect resources on adjacent federal, tribal,

or non-federal land.

Title: WILDLIFE DAMAGE MANAGEMENT ACTIVITIES ON NATIONAL

FOREST SYSTEM LANDS

I. PURPOSE:

The purpose of this agreement is to document the cooperation between the parties: (1)

to identify responsibilities of the Parties and foster a partnership in discharging the

Federal obligation under the Act of March 2, 1931 (46 Stat. 1468:7 U.S.C. 426-426b),

as amended, the Act of December 22, 1987 (101 Stat. 1329-331. 7 U.S.C. 426c)

Executive Order 13112, and the 2008-2012 National Invasive Species Management 

Plan for the management of indigenous and invasive vertebrates causing damage on

NFS land; (2) to establish general guidelines to assist field personnel in carrying out

their WDM responsibilities consistent with policies of the Forest Service and APHISWS; and (3) to strengthen the cooperative approach to WDM on NFS lands through 

exchange of information and mutual program support in accordance with the following

provisions.
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 70

In consideration of the above premises, the parties hereto agree as follows:

D. THE APHIS WS SHALL:

A. Evaluate WDM needs in cooperation with the U.S. Forest Service.

B. Develop and annually update WDM work plans in cooperation with the U.S.

Forest Service and appropriate State and Federal agencies, tribes, permittees, and

others. With the U.S. Forest Service, identify human health and safety zones and

other areas where mitigation or restriction of WDM activities may be needed to

comply with forest plans.

C. Be responsible for NEPA compliance for wildlife damage, invasive and wildlife

disease management activities initiated by APHIS-WS and other WDM activities

as agreed upon by APHIS-WS on NFS lands and to coordinate with the FS and

appropriate State and local agencies and tribes in completing the NEPA process for

such activities. The FS will be responsible for NEPA compliance for any WDM

activities not covered above.

D. Notify the U.S. Forest Service about WDM requests prior to the execution of WDM

activities.

E. Inform the U.S. Forest Service about the results of WDM activities initiated

by APHIS-WS in a timelymanner. Additionally, provide the U.S. Forest Service

with an annual report, by State, summarizing the results of all WDM on NFS

lands. The annual report shall list the names and amounts of pesticides used.

F. Provide the U.S. Forest Service with technical information on WDM tools and

techniques. 

G. Conduct WDM training sessions for U.S. Forest Service personnel.

III. THE FOREST SERVICE SHALL:

A. Cooperate with APHIS-WS in the development and timely review of annual

WDM plans governing APHIS-WS activities, including pesticide-use proposals.

B. Participate in APHIS-WS NEPA processes as appropriate. The U.S. Forest Service will

be responsible for NEPA compliance on activities as defined in Section IV. A. below.

C. Invite APHIS-WS participation in all applicable U.S. Forest Service training at the

national, regional, and forest levels, especially NEPA and Wilderness training.

D. Involve APHIS-WS in the amendment/revision of forest plans which may have an

impact on WDM activities.
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 71

IV. IT IS MUTUALLY AGREED AND UNDERSTOOD BY AND BETWEEN THE 

PARTIES THAT:

A. The U.S. Forest Service is responsible for managing land and resources under its

jurisdiction, including conducting certain routine WDM operations to protect NFS

lands and resources, and for assuring NEPA compliance for WDM activities requested

or initiated by the U.S. Forest Service.

B. APHIS-WS has been granted the authority and expertise under the Act of March 2,

1931 (46 Stat. 1468; 7 U.S.C. 426–426b), as amended, and the Act of December 22, 

1987 (101 Stat. 1329-331, 7 U.S.C. 426c) to provide WDM services. This includes

maintaining technical expertise in the science of WDMcontrol tools and techniques,

conducting WDM research, conducting management programs, conducting wildlife

disease surveillance, and complying with NEPA requirements for WDM.

C. All WDM programs on NFS lands will be coordinated with appropriate State, Tribes, and

Federal agencies prior to implementation of these programs.

D. WDM on NFS lands will be carried out in conformance with the Endangered Species

Act, Wilderness Act and other applicable laws and regulations, USDA policy on fish

and wildlife Departmental Regulation 9500-4), U.S. Forest Service policies, and

applicable forest land and resource management plans.

E. Parties will comply with all applicable Federal,State, and local laws and regulations 

in the use and application of pesticides.

F. State WDM agreements will be developed, as needed with the appropriate State, Tribes,

and Federal agencies.

G. Both parties will ensure interagency coordination in analyzing the effects of WDM

activities by APHIS-WS on NFS lands and resources before NEPA decisions are

signed. The agency responsible for implementation of a specific project will also be

responsible for completion of NEPA analysis and documentation.

H. The WDM Programs will be evaluated on an annual basis, with emphasis on their

effectiveness in reducing damage or the threat of damage by wildlife and meeting the

objectives stated in this agreement and APHIS-WS relevant NEPA documents.

I. The APHIS-WS Deputy Administrator and the U.S. Forest Service Deputy Chief for

National Forest System (or their designees) will meet annually to discuss coordination of

WDM operations nationwide. APHIS-WS Regional Directors and U.S. Forest Service

Regional Foresters (or their designees) will meet annually, or as needed to discuss

coordination of WDM operations in their respective States or regions.

J. Problemsregarding implementation of this agreement that arise and cannot be resolved

at the field level will be reviewed and resolved by elevating to the next higher

organizational level for prompt action. In the event of any issue of controversy under

the Agreement, the Parties may pursue Alternate Dispute Resolution procedures to
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 72

voluntarily resolve those issues. These procedures may include, but are not limited to,

conciliation,facilitation, mediation, and fact-finding.

K. The Parties will cooperate on WDM research of mutual interest.

L. The partiesshall manage their respective resources and activities in a separate,

coordinated, and mutually beneficial manner to meet the purposes of this agreement. 

Nothing in this agreement authorizes any of the parties to obligate or transfer funds.

Specific projects or activities that involve the transfer of funds, services, or property

among the partiesrequire execution of separate agreements and are contingent upon the

availability of appropriated funds. Each party operates under its own laws, regulations, and

policies, subject to the availability of appropriated funds.

M. PRINCIPAL CONTACTS. Individuals listed below are authorized to act in their

respective areas tor matters related to this instrument.

Principal Cooperator Contacts:

Cooperator Program Contact Cooperator Administrative Contact

Name: Deputy Administrator. Bill Clay

Address: USDA Animal & Plant Health 

Inspection Service. Wildlife Services,

Mail Stop 3402

City, State, Zip: Washington, DC 20250-3402

Telephone: (202) 720-2054

FAX: (202) 690-0053

Email: bill.clay@aphis.usda.gov

Name: Joanne Garrett

Address: USDA Animal & Plant Health

Inspection Service. Wildlife Services, 4700

River Rd., Unit 87. Room 2026

City. State. Zip: Riverdale. MD 20737-1234

Telephone: (301) 734-7921

FAX: (301) 734-5157

Email: joanne.p.garrett@aphis.usda.gov

Principal U.S. Forest Service Contacts:

U.S.Forest Service Program Contact U.S. Forest Service Administrative Contact

Name: Anne Zimmermann

Address: USDA Forest Service, Watershed, 

Fish, Wildlife, Air, and Rare Plants, 1400

Independence Ave., SW. Stop Code 1121

City, State. Zip: Washington, DC 20250-1121

Telephone: (202) 205-1167

FAX: (202) 205-1599

Email: azimmermann@fs.fed.us

Name: Felicia Lockhart

Address: USDA Forest Service, Watershed, 

Fish. Wildlife, Air, and Rare Plants. 1400

Independence Ave., SW, Stop Code 1121

City. State, Zip: Washington, DC 20250-1121

Telephone: (202) 205-1197

F :(202)205-1599

Email: flockhart@fs.fed.us

N. USE OF U.S. FOREST SERVICE INSIGNIA. In order for APHIS-WS to use

the U.S. Forest Service Insignia on any published media, such as a Web page,

printed publication, or audiovisual production, permission must be granted from

the U.S. Forest Service’s Office of Communications. A written request must he
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 73

submitted and approval granted in writing by the Office of Communications

prior to use of the insignia.

0. U.S. FOREST SERVICE ACKNOWLEDGED IN PUBLICATION,

AUDIOVISUALS, AND ELECTRONIC MEDIA. APHIS-WS shall acknowledge 

U.S. Forest Service support in any publications, audiovisuals, and electronic media

developed as a result of this instrument.

P. NONDISCRIMINATION STATEMENT-PRINTED, ELECTRONIC,OR

AUDIOVISUAL MATERIAL. APHIS-WS shall include the following statement, in

full, in any printed, audiovisual material, or electronic media for public distribution

developed or printed with any Federal funding.

"In accordance with Federal law and U.S. Department of

Agriculture policy, this Institution is prohibited from

discriminating on the basis of race, color, national origin, sex, age,

or disability. (Not all prohibited bases apply to all programs.)

To file a complaint of discrimination, write USDA. Director, Office of Civil

Rights, Room 326-W, Whitten Building, 1400 Independence Avenue, SW,

Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). 

USDA is an equal opportunity provider and employer."

If the material is too small to permit the fullstatement to be included, the material

must, at minimum, include the following statement, in printsize no smaller than the

text:

''This institution is an equal opportunity provider.''

Q. TERMINATION. Any of the parties, in writing, may terminate this MOU in whole,

or in part, at any time before the date of expiration.

R. NONBINDING AGREEMENT. This MOU creates no right, benefit, or trust

responsibility, substantive or procedural, enforceable at law or equity. The partiesshall

manage their respective resources and activities in a separate, coordinated and mutually

beneficial manner to meet the purpose(s) of this MOU. Nothing in this MOU authorizes

any of the parties to obligate or transfer anything of value.

Specific, prospective projects or activities that involve the transfer of funds,services, 

property, and/or anything of value to a party requires the execution of separate

instruments and are contingent upon numerous factors, including, as applicable, but

not limited to: agency availability of appropriated funds and other resources;

cooperator availability of funds and other resources; agency and cooperator

administrative and legal requirements (including agency authorization by statute): etc.

This MOU neither provides, nor meetsthese criteria. If the parties elect to enter into

an obligation instrument that involvesthe transfer of funds,services, property, and/or
APPENDIX B

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 74

anything of value to a party, then the applicable criteria must be met. Additionally,

under a prospective instrument, each party operates under its own laws, regulations.

And/or policies, and any Forest Service obligation issubject to the availability of 

appropriated funds and other resources. The negotiation, execution, and

administration of these prospective instruments must comply with all applicable law.

Nothing in this MOU is intended to alter, limit, or expand the agencies' statutory

and regulatory authority.

S. ALTERNATE DISPUTE RESOLUTION-INTERAGENCY. The parties to this

agreement shall settle any disputes that may arise under this agreement by following

direction in the Treasury Financial Manual, Volume 1, Bulletin 2007-03, Section VII

("Resolving lntragovernmental Disputes and Major Differences”).

T. MODIFICATIONS. Modifications within the scope of this instrument must be made

by mutual consent of the parties, by the issuance of a written modification signed and

dated by all properly authorized, signatory officials, prior to any changes being

performed. Requests for modification should be made, in writing, at least 30 days prior

to implementation of the requested change.

U. FREEDOM OF INFORMATION ACT (FOIA). Public access to agreement records

must not be limited, except when such records must be kept confidential and would 

have been exempted from disclosure pursuant to Freedom of Information regulations

(5 U.S.C. 552).

V. ENDORSEMENT. Any of APHIS-WS's contributions made under this agreement

do not by direct reference or implication convey U.S. Forest Service endorsement 

of APHIS-WS's products or activities.

W. NOTICES. Any notice given by the U.S. Forest Service or APHIS-WS will be

sufficient only if in writing and delivered in person, mailed, or transmitted

electronically by e-mail or fax, as follows:

To the U.S. Forest Service Program Manager, at the address specified in the grant.

To APHIS-WS, at the address shown in the grant or such other address

designated within the grant.

X. PARTICIPATION IN SIMILAR ACTIVITIES. This agreement in no way restricts the

U.S. Forest Service or APHIS-WS from participating in similar activities with other

public or private agencies, organizations, and individuals.

Y. COMMENCEMENT/EXPIRATION DATE. This instrument is executed as of the

date of the last signature and is effective through April 15, 2016 at which time it will

expire, unless extended by an executed modification signed and dated by all properly

authorized, signatory officials.
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Z. CONGRESSONAL RESTRICTION. Under 41 USC 22, no member of, or

delegate to, Congress shall be admitted to any share or part of the MOU or to

any benefit to arise therefrom.

AA. LIABILITIES. APHIS will hold the Cooperator harmless from any liability arising

from the negligent act or omission of the APHIS officer or employee acting within

the scope of his or her employment to the extent compensation is available pursuant

to the Federal Tort Claims Act (FTCA). 28 USC 2671 et. seq., except to the extent

that aforesaid liability arises from the negligent acts or omissions of the Cooperator, 

its employees, agents or subcontractor, and employees or agents of the

subcontractor(s). Such relief shall be provided pursuant to the procedures set for in

the FTCA and applicable regulations.
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Appendix C: Risk Assessment of Potential Direct Control Methods Used by APHIS WS

The following excerpts were taken from the USDA 1997 Risk Assessment, Appendix P, pages 

13-34 and 278. 

USDA. 1997, revised. Animal damage control program, final environmental impact statement. 

Appendix P. Risk Assessment of Wildlife Damage Control Methods Used by the USDA 

Animal Damage Control Program. United States Department of Agriculture, Animal and 

Plant Health Inspection Service, Animal Damage Control [Wildlife Services], Operational 

Support Staff, Riverdale, Maryland, USA.

And 

USDA. 2005. Final Environmental Assessment (EA): Predator Damage Management in 

Colorado. USDA APHIS-WS, Denver, CO.

1. Introduction

This risk assessment provides an analysis of the risks to nontarget animals, workers, and the 

public posed by nonchemical methods which may be used for wolf damage management by 

APHIS Animal Damage Control (ADC) (hereafter referred to as APHIS WS). 

2. Risk Assessment Procedure

For each nonchemical method, the potential risks to employees, the public, and nontarget species 

were characterized in either qualitative or quantitative terms. Qualitative characterizations of 

potential risks were developed for resource management, physical exclusion, and some resource 

management methods. These methods are largely recommended by APHIS WS (technical 

assistance) and implemented by resource owners or managers. Initial review of the methods 

suggested that they did not pose risks requiring quantitative analysis. In qualitative terms, risks 

to the environment or to human health and safety are characterized as "low," "moderate," or 

"high." Because many of the remaining wildlife management methods may result in injury or 

death to nontarget species or may result in injury to humans (especially APHIS WS employees), 

a quantitative analysis of these methods was appropriate.

The quantitative analyses were based on data compiled for the six states that used APHIS WS's 

Management Information System (MIS) in 1988: Arizona, California, New Mexico, Oklahoma, Texas, 

and Utah. The MIS provided the most extensive and consistent database of information about 

target and nontarget take and the most relevant information for assessing environmental risk.

Although other States used nonchemical methods, these six states accounted for the largest 

proportion of use of many controversial nonchemical methods (such as trapping). The measure 

of environmental risk for each of these methods was the number of nontarget animals captured as 

a percentage of the number of captures. This measure was chosen because it is a conservative 

measure. Many animals captured by APHIS WS are released unharmed. The proportion of such 

animals released varies by method. Because many animals are released, potential risk may be 

overestimated.
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Assessment of potential risks to APHIS WS workers was based on data compiled from injuries 

reported to the APHIS Health and Safety Office. These reports were supplemented by records 

from APHIS WS State Offices to ensure that non-Federal APHIS WS employee injuries were 

included. The reported injuries were in some cases associated with the use of specific control 

methods. When reporting an injury, APHIS WS employees provide information about the injury 

and the circumstances that led to it. This information was used to identify serious injuries and 

associate them, where possible, with the method used by the injured employee. For this analysis, 

a "serious injury" was any injury requiring time away from the job. This is a very conservative 

concept of serious injury. Since the total number of injuries to employees was small, no 

constructed measures of risk were used. The information is presented in its entirety in the 

discussions in the text.

Assessment of risks to the public was based on data compiled from a questionnaire completed by 

APHIS WS State Directors in December 1991 and January 1992. The State Directors were 

asked to supply the number of recorded injuries to the public during 1988-91, along with details 

of such injuries.

3. Wildlife Management

Wildlife management methods move or remove wildlife responsible for damage. Non-chemical 

wildlife management methods include habitat management, the use of lure crops and alternate 

foods, frightening devices, and kill or relocation methods. Wildlife management methods are 

implemented by APHIS WS through direct control, or recommended through technical assistance.

In the following sections, the use patterns and environmental risks of each of the non-chemical 

wildlife management methods discussed in the EA are presented. Because these methods are 

usually implemented in an outdoor setting, many of the risks to human health and safety are 

similar to the risks posed by any outdoor occupation. Where reported injuries are associated 

with particular control methods, appropriate discussion is included. A more extensive discussion 

of potential human health risks is included at the end of the nonchemical risk evaluation.

A. FrighteningDevices

(1) Use Patterns

Frightening devices are used to scare animals from damage sites. Recorded animal distress and

alarm calls can be played back at intervals or continuously to frighten target species. Propane

exploders and pyrotechnics produce loud explosions at controllable intervals to frighten target

species.

Bright lights, flashing lights, and strobe lights sometimes are used to frighten animals that feed

at night. Combinations of powerful strobe lights and sirens have also been used to frighten

coyotes [and wolves], and avert depredation of sheep.

Harassment also can frighten predators and help to avoid wildlife damage. Human activity,

dogs, boats, planes, automobiles, and all-terrain vehicles are used as harassment methods.
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(2) Hazards

Human Health and Safety

The use of harassment devices may affect human health and safety due to auditory and visual

disturbances.

Environmental

There is a potential risk of fire from the use of propane exploders or pyrotechnics, particularly if

used in grassy areas during dry periods. The use of vehicles may lead to erosion problems or

injuries to nontarget animals. Improper or inappropriate use of any of the harassment

techniques may result in disturbances to nesting animals. Nontarget animals may be adversely

affected because of loss or inaccessibility to food sources or other habitat components.

(3) Risks

Human Health and Safety

APHIS health and safety records do not show any accidents associated with use of this method. 

Short-term human disturbance may result from the use of auditory or visual frightening devices.

Environmental

As used by APHIS WS, injury to nontarget animals is minimal. APHIS WS does not

recommend practices nor conduct activities that would jeopardize federally threatened or

endangered species.

B. Kill or RelocationMethods

(1) LegholdTraps

(a) Description

Leghold traps are mechanical capture devices comprised of a pair of jaws, one or more

springs, a base to which the jaws and springs are attached, and a triggering mechanism that

secures the trap in a set position until it is stepped on by an animal. A leghold trap captures an

animal by gripping its leg or foot. The two basic designs of leghold traps used in the APHIS

WS program are coil-spring and long-spring traps. Leghold traps are available in many sizes. 

Each size is designed for a specific size class of animal and generally categorizes the width of

the jaws. Sizes used in the APHIS WS program range from the No.1, which is used for small

animals, to the No. 7, which is used for mountain lions.

Leghold traps are used by APHIS WS personnel to capture the greatest variety of species of any

of the control methods used in the APHIS WS program. Accordingly, leg- hold traps are one of

the most versatile control methods used by the APHIS WS program. The devices are used in a

wide variety of habitat types and damage situations. These devices are used in both aquatic and

terrestrial habitats to capture animals for translocation or lethal removal. Use-pattern data

indicates that this method is used throughout the year. Leghold traps were also used in wildlife

damage control operations in APHIS WS programs other than in the six MIS reporting states.

Leghold traps are either placed beside or, in specific situations, in travel ways being actively

used by the target species. Placement of these traps is contingent upon the habits of the

respective target species, habitat conditions, and presence of nontarget animals. In terrestrial

settings, leghold traps are placed without baits in travel ways to capture target animals that are

routinely using specific routes in the damage area. They are also placed in proximity to
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commonly used travel ways along with a bait, scent, or lure that serves as an attractant to draw

target animals to the traps. Baited traps may also be located in the vicinity of animal carcasses

to capture depredating predators that are naturally drawn to the site. In aquatic settings, use is

primarily in shallow water at entrance or exit trails or at territorial markings used by target

animals. Most aquatic sets are made as drowning sets.

Within applicable restriction of respective State laws, leghold traps are used or may be used

nationwide in the APHIS WS program. Leghold traps are used primarily in rural areas on

private and public lands.

(b) Hazards

Human Health and Safety

Human health and safety hazards associated with use of leghold traps are minor. Minor cuts,

bruises, abrasions, or fractured bones in the fingers and hands of users may result from handling

or accidental discharge of traps during placement. Injuries are related to setting and placement

of the devices, making APHIS WS personnel the most vulnerable to hazard exposure. Trap

placement and removal may also result in muscle and back strains. Repeated kneeling to set 

traps can also result in knee and back strains. Removal of animals from traps exposes users and

the public to bites and scratches.

Environmental

Environmental hazards associated with the use of leghold traps include injury or death of target 

and nontarget animals. Injuries that may occur include cuts, sprains, broken bones, or

interruption of circulation. These injuries may result from the force of the trap closing, efforts

of the captured animal to escape, or the length of time that the animal remains in the trap. Death

may result from exposure to the elements, post-capture euthanasia by the APHIS WS technician,

or post-release complications. Traps placed to capture one species may capture animals of

another species; and traps placed to capture predators may also capture livestock. Traps placed

near carcasses to capture predators present a hazard to scavengers, and traps placed in areas 

frequented by domestic pets present hazards to those animals.

(c) Risks

Human Health and Safety

Risks of human injury by leghold traps are generally restricted to APHIS WS employees

involved in the placement and use of these devices. The use of these devices in rural and urban

environments results in exposure to the public, but is primarily restricted to the property or

resource owners, or managers (or employees) who receive APHIS WS assistance. Placement of

leghold traps is generally confined to areas not visible to or frequently visited by the public.

This further minimizes risk of exposure to the public.

Human health and safety risks to the public are minimized by program guidelines that require

warning signs to be posted in the vicinity of control operations. There were no reports of

injuries to the public related to the placement of leghold traps by APHIS WS personnel in 1988.

Training, experience, the use of gloves, trap-setting devices, trap-stake pullers, and other aids

ensure the safety of employees. Employee use is evaluated frequently to ensure continued

adherence to program guidelines and safety standards. APHIS WS program injury records for
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the six MIS states indicates five injuries to APHIS WS personnel related to use of leghold traps

in 1988.

Environmental

Environmental risks are greatest for animals that frequent the area where leghold traps are

placed. Leghold traps are used in a variety of habitats, thus many species of wildlife are

exposed to leghold traps used by APHIS WS personnel. Nontarget risks are minimized by the

selection of appropriate trap size, use of pan tension devices, selection of the appropriate

attractant, or bait, and proper site-selection.

Selection of proper trap size generally minimizes risks to nontarget animals that are significantly

larger than the target species. P an tension devices generally minimize risks to species weighing

less than the target species. Development and use of the appropriate bait, scent, or lure in

recognition of the preferences of target and nontarget species minimizes the risks to nontarget

animals. Proper site selection increases the likelihood of exposure to the target species while

minimizing exposure to nontargets. Site selection involves an understanding of the home

ranges, habitat preferences, travel patterns, and population densities of the species present in the

area where control operations are being conducted. APHIS WS program policy also influences

site selection by requiring traps placed near animal carcasses to be at least 30 feet away from the

carcass. This provides protection for scavenging species.

Protection of domestic pets is generally accomplished by public notices in the form of area

warning signs placed in the vicinity of control operations. These signs, which advise the public

to restrain their pets, are placed at commonly used access points and along property boundary

fences.

In 1988, the six MIS states reported a total take by leghold traps of 21,992 animals. Of these,

16,865 were target animals and 5,127 were nontargets. The total nontarget take represented 37

species and 23.31 percent of all animals taken by this method. Of the nontarget animals taken,

59.74 percent were destroyed. 

No federally listed threatened or endangered species were taken as nontargets as a result of 

APHIS WS program use of leghold traps in 1988.

(2) Cage Traps

(a) Description

Cage traps, which are used to capture animals ranging in size from mice to bear, have limited

application in capturing most large animals. These devices are used primarily on land to capture

animals for translocation or lethal removal. Cage traps are normally placed near travel ways and

baited with food items as attractants. Capture results from mechanical closure of the entry way

via the animal's actuation of a triggering device upon entry, or by the physical construction of

the trap opening which allows one-way access only. Placement of the devices is dependent upon

the respective target species' habits and habitat conditions and is set to minimize exposure to and

capture of nontarget animals.
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Cage traps commonly used by APHIS WS include drop-door wire or solid door box traps for 

small mammals such as skunks and raccoons; walk-in wire box traps for pigeons, blackbirds,

and vultures; walk-in drive traps for flightless waterfowl; suitcase-type Hancock or Bailey traps

for beaver; and drop-door culvert traps for bears.

Species primarily captured by this method in the six MIS states in 1988 were skunks, raccoons, 

opossums, and blackbirds. Cage traps were also used in wildlife damage control operations in 

APHIS WS programs other than in the six MIS reporting States. 

Cage traps may be used nationwide in the APHIS WS program on privately or publicly owned 

properties. Use is most frequent in urban areas.

(b) Hazards

Human Health and Safety

Human health and safety hazards associated with use of cage traps are minor. Slight cuts or 

abrasions to hands, fingers, or arms may result from contact with sharp wire ends. The removal 

of animals from cage traps may result in animal bites.

Environmental

Environmental hazards associated with the use of cage traps are injury or death of nontarget 

animals. Use of this trap type usually allows release of captured nontarget animals. Death may 

occur as a result of entanglement, exposure to the elements, or post-capture euthanasia when 

release is impractical due to trap-related injury.

(c) Risks

Human Health and Safety

Exposure to human health and safety hazards is minimized as a result of program-implemented 

procedures. Extensive training and experience of employees ensure development and 

employment of the skills required to use these devices in a safe and effective manner. Employee 

use is evaluated frequently to ensure continued safe use practices.

Risk of human injury by cage traps is largely restricted to APHIS WS employees involved in 

placement and use. A review of APHIS WS program injury records reveals no reportable injuries 

to APHIS WS personnel directly attributable to the use of cage traps in 1988. There were no 

reports of injuries to non-APHIS WS personnel. The use of these devices in rural and urban 

environments results in exposure to the public, but human health and safety risks are minimal.

Environmental

Environmental risks are minimized through APHIS WS program implemented features and 

factors leading to increased selectivity. Proper placement and maintenance of cage traps will 

generally allow unharmed release of nontarget animals. APHIS WS operating procedures include 

the physical placement of cage traps and use of appropriate lures or scents to maximize exposure 

to target animals and the checking of traps as frequently as possible.

Cage traps are used in a variety of habitats; thus, risks are greatest for those animals that are 

likely to frequent the areas in which this equipment is placed and which are likely to enter the 

device. Risks are largely dependent upon an animal's attraction to baits within the trap, trap 
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placement, and the animal's body size. For example, a skunk trap baited with fish would pose no 

risk to bears because of trap size; likewise, a bear culvert trap baited with the same bait and 

positioned 2 feet off the ground would pose no risk to skunks because of inaccessibility.

In 1988, the six MIS states reported a total take by this method of 16,462 animals, of which 195 

were nontargets. The nontarget take represented 13 species groups and 1.2 percent of all animals 

taken by this method. Of the nontarget animals taken, 42.05 percent were destroyed.

No federally threatened or endangered species were taken by APHIS WS use of cage traps.

(3) Quick-kill Traps

(a) Description

Quick-kill traps include several specialized traps such as the Conibear style body-grip trap, and 

snap, gopher, and mole traps. These devices either crush captured animals between opposing 

metal jaws or between the jaw and a wooden or plastic base, or impale the animal with sharp 

metal spikes in subterranean travel ways. These devices are powered by strong metal coil

springs.

Quick-kill traps are designed to cause the quick death of the animals that activate the devices. 

These traps are primarily used to control rodent damage. The use of quick-kill traps in the 

APHIS WS program is primarily limited to Conibear style traps, which are employed to control 

damage caused by mammals such as the beaver, nutria, and muskrat. These traps are used 

almost exclusively in aquatic habitats, with placement depths varying from a few inches to 

several feet. Placement is in travel ways or at lodge or burrow entrances created or used by the 

target species. The animal is captured as it travels through the trap and activates the triggering 

mechanism.

Snap traps are commonly used to control mice, rats, and voles in and around residential, 

industrial and agricultural buildings. These traps may also be used in some circumstances to 

control squirrels and other rodents. APHIS WS use of these traps is primarily limited to 

technical assistance involving advice and demonstrations to others on the proper use of these 

devices. Gopher and mole traps are designed specifically for the species for which they are 

named. These devices are designed to control both species within their subterranean habitats. 

APHIS WS use of these devices is also limited primarily to technical assistance involving advice 

and demonstrations to others on the proper use of these devices.

Species primarily captured by quick-kill traps in the six MIS states in 1988 were beaver and 

nutria. Use pattern data indicates that this method is used throughout the year, but is greatest 

during the spring, summer, and fall months. This method was also used in APHIS WS programs 

in states other than the six MIS reporting states. 

Within applicable restrictions of respective state laws, quick-kill traps may be used nation-wide 

in the APHIS WS program. They are used primarily in rural, private land areas but may 

occasionally be used in urban or suburban areas and on publicly-owned properties.
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(b) Hazards

Human Health and Safety

Human health and safety hazards associated with use of quick-kill traps varies with trap size and 

type. Minor injuries, including cuts, bruises, or abrasions, may occur to the fingers and hands 

from handling and setting the smaller traps. The large beaver-size Conibear style trap is capable 

of causing more serious injury such as bone fractures in arms, hands, and fingers. Safety hazards 

are usually related to setting, placing, checking, or removing the devices.

Environmental

Environmental hazards include injury or death of nontarget animals. Hazards to nontargets are 

generally confined to a small area in the vicinity of the damage site. Most animals captured in 

these traps die quickly. A small percentage of the animals captured in these traps may be 

released.

(c) Risks

Human Health and Safety

Risks of human injury associated with the use of quick-kill traps are generally restricted to the 

users of these devices. The use of these devices in rural and urban environments results in 

exposure to the public, but is primarily restricted to property or resource owners or managers, or 

employees who receive APHIS WS assistance. No APHIS WS employee injuries directly 

attributable to quick-kill trap use were reported in 1988. Additionally, there were no reports of 

injuries to the public attributable to quick-kill traps placed by APHIS WS personnel.

Human health and safety risks to the public are minimized by program guidelines which require 

warning signs to be posted in the vicinity of control operations. Placement of quick-kill traps in 

aquatic environments and on predominantly private lands in areas generally not visible or 

accessible to the public also minimizes the exposure of these devices to the public. Extensive 

training of new employees ensures development of the skills required to use and demonstrate the 

use of these devices in a safe and effective manner. Employees are evaluated frequently to 

ensure continued adherence to program guidelines and safety standards.

Environmental

Environmental risks associated with the use of Conibear style quick kill traps are generally 

limited to aquatic species in the general area where these traps are placed. Environmental risks 

associated with the use of snap traps are generally limited to domes- tic animals since these traps 

are normally used in and around residential, industrial, and agricultural buildings. 

Environmental risks associated with the use of mole and gopher traps are minimal since few, if 

any, nontarget animals occupy the subterranean habitat where these devices are placed.

Environmental risk to nontarget animals is also minimized through the selection and use of the 

appropriate size of trap. Conibear style traps commonly used in beaver control operations present 

a minor risk to many small nontarget animals because they are small enough to safely pass 

through the trap without disturbing the triggering mechanism. Conversely, small traps present 

little risk to animals that are too large to enter the traps. Placement of these devices at or in den 

or burrow entrances of target species minimizes nontarget exposure since the target animals are 

the most frequent users of these openings.
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In 1988, the six MIS states reported a total take by this method of 4,856 animals; of these 4,797 

were target animals and 59 were nontargets. The total nontarget take represented 6 species and 

1.2 percent of all animals taken by this method. All nontarget animals were destroyed. No 

federally listed threatened or endangered species were taken.

(4) Snares

(a) Description

Snares are capture devices comprised of a cable loop and a locking device. Most snares are also 

equipped with one or more swivels to minimize cable twisting and breakage. Snares are 

designed to tighten around an animal's body as it passes through the device. A snare may be 

placed in a vertical position to capture an animal as it passes through the loop, or it may be used 

horizontally with a trigger and spring activated throw-arm to capture the animal by the leg when 

it steps in the loop. Catch poles are hand-held snaring devices used primarily to remove live 

animals from traps or confined areas such as buildings, without danger to or from the captured 

animal.

Snares are used by APHIS WS personnel primarily to control damage caused by mammals such 

as beaver, coyote, mountain lion, and bear. These devices are used in aquatic and terrestrial 

habitats to capture animals for translocation or lethal removal. Use-pattern data indicates that 

this method is used throughout the year. Snares were also used in APHIS WS programs in states 

other than the six MIS reporting states. Snares are normally placed in travel ways, and capture is 

around the neck, body, or leg. APHIS WS personnel generally use two types of sets; trail sets 

and baited sets. In both situations, the snares are placed in restricted travel ways where the 

animal is forced to travel over or through the device. Most neck or body snares used in 

terrestrial habitat are placed in or under fences where evidence indicates that the target animal is 

entering the area where damage is occurring. Neck snares used in aquatic habitat are usually 

placed in shallow water at water entrance or exit trails, lodge entrances, or territorial marking 

sites used by target animals. Placement of snares is dependent upon the habits of the respective 

target species and habitat conditions. Placement location is selected to minimize exposure to and 

capture of nontarget animals. 

Within applicable restrictions of respective state laws, snares are used or may be used nationwide in the APHIS WS program. Dependent upon snare type and circumstance, use may occur 

in rural or urban areas and on privately or publicly-owned properties.

(b) Hazards

Human Health and Safety

Human health and safety hazards associated with use of snares are minor. Abrasions, bruises, 

and minor cuts to the fingers, hands and arms of users may result from inadvertent release of the 

spring mechanism of leg snares. Minor cuts to hands and fingers may also occur from broken 

strands of cable or frayed cable ends.

Environmental

Environmental hazards associated with the use of snares are injury or death of nontarget animals. 

Injuries generally involve abrasions, cuts, and bruises or constriction of blood flow. Death may 

result from strangulation, exposure to the elements, or humane disposal by an APHIS WS 

technician.
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(c) Risks

Human Health and Safety

Risk of human injury by snares is generally restricted to APHIS WS employees involved in 

placement and use of snares. The use of these devices in rural and urban environments results in 

exposure to the public but is generally restricted to property or resource owners who receive 

APHIS WS assistance. No employee injuries directly attributable to snare use were reported in 

1988. Additionally, there were no reports of injuries to the public attributable to snares placed by 

APHIS WS personnel.

Human health and safety risks to the public are minimized by program guidelines that require 

warning signs to be posted in the vicinity of control operations. Training, experience, and the 

use of gloves to protect hands and fingers ensure the safety of employees. Employee use is 

evaluated frequently to ensure continued adherence to program guidelines and safety standards.

Environmental

Environmental risks are greatest for animals that frequent the area where snares are placed and 

travel along the paths of the target species. Neck and body snares are used in a variety of 

habitats; thus, many species of wildlife are exposed to snares used by APHIS WS personnel. 

Nontarget risks are minimized by adjustment of loop size and height of placement. Proper loop 

size and height placement allows animals smaller than the target species to pass through or under 

the devices unharmed. Leg snares are generally used to capture bears and mountain lions. The 

limited distribution and use of these devices minimizes the exposure of leg snares to nontarget 

animals. Pan tension devices exclude the capture of animals weighing less than the target 

species.

In 1988, the six MIS reporting states reported a total take by this method of 8,581 animals; of 

these, 6,944 were target animals and 1,637 were nontargets. The total nontarget take represented 

22 species and 19.1 percent of all animals taken by this method. Of the nontarget animals taken, 

90.78 percent were destroyed. No federally listed threatened or endangered species were taken 

by the APHIS WS program as a result of the use of snares.

(5) Shooting

(a) Description

Ground shooting, with rifles and shotguns, is employed to remove target animals through 

harassment or lethal removal. Shooting for harassment purposes generally involves the use of 

shotguns. Shooting in the direction of, but not at. target animals is sometimes augmented by 

intentional shooting of individual target animals. The intent of such shooting is to enhance the 

scaring efficiency of firearms and pyrotechnics by training the birds to anticipate injury when 

they hear explosions. This method is often applied in behavior management of birds such as 

blackbirds, crows, cormorants, and herons.

Shooting to kill may be accomplished by shooting on sight or by calling and shooting. This 

method may be employed in various habitat types, at night or during the daytime, using shotguns 

and small and large caliber rifles. Species primarily removed by this method in the six MIS 

states in 1988 were coyotes, beaver, and blackbirds. Shooting was also used in wildlife damage 
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control operations in APHIS WS programs other than in the six MIS reporting states. It is also 

employed to humanely destroy animals captured in various capture devices.

Shooting is used, or may be used, throughout the year in the APHIS WS program and is most 

frequently used in rural areas on privately or publicly owned properties.

(b) Hazards

Human Health and Safety

Human health and safety hazards associated with use of shooting are highly variable, dependent 

primarily upon the skill of the user and firearm type. Hazards to the user may include: shoulder 

bruises from firearm recoil, hearing damage from sustained noise exposure without proper 

hearing protection, eye damage from fired ammunition debris, and self-inflicted gunshot due to 

improper firearm handling. Hazards to the non-user include hearing damage, if in close 

proximity to the firearm, and gunshot wound.

Environmental

Environmental hazards associated with shooting are minimal. Hazards to nontargets are 

confined to animals which may be mistakenly identified or those which inadvertently enter the 

path of firearms during harassment activities.

(c) Risks

Human Health and Safety

The primary human health and safety hazard associated with shooting is related to firearms 

handling by the user, making APHIS WS personnel the most vulnerable. Human health and 

safety risks are minimized as a result of program-implemented safety practices. Extensive 

training and experience of employees ensure development and employment of the skills required 

to use firearms in a safe and effective manner. Firearms are employed safe distances from 

human habitations and other activities, and are fired in safe directions only. Employee use is 

evaluated frequently to ensure continued safe-use practices.

A review of APHIS WS program injury records reveals no reportable injuries to the public or 

APHIS WS personnel attributable to shooting in 1988.

Environmental

Environmental risks are greatest for those nontarget animals similar in appearance to target 

animals. Environmental risks are minimized through training of APHIS WS personnel in species 

identification, resulting in shooting as a highly selective damage control method. The various 

types of shooting activities are very selective in taking target animals and may be used in areas 

where exposure to sensitive species is likely.

In 1988 the six MIS states reported a total take by shooting of 10,897 animals of which 20 were 

nontargets. The nontarget take represented 6 species groups and 0.18 percent of all animals 

taken by this method. All nontarget animals were destroyed.

No federally listed threatened or endangered species were taken by the APHIS WS use of 

shooting.
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(6) Aerial Hunting

(a) Description

Light fixed-wing aircraft and helicopters are used extensively for the hunting or hazing of 

animals to alleviate damage and for the taking or capturing of animals for various research 

projects. Aerial hunting involves the removal of target animals through shooting from 

helicopters or fixed-wing aircraft; this method is used primarily to control livestock losses 

caused by coyotes. Aerial hazing involves the use of aircraft to harass or frighten populations of 

depredating birds; this method is used primarily to control crop losses caused by depredating 

birds. Aerial hunting and hazing are used primarily in rural areas of the Western States on 

private and public properties. All flight activities are conducted in accordance with the Airborne 

Hunting Act (50 CFR Chapter 1, Part 19), Federal Aviation Agency regulations, and APHIS WS 

program Aviation Safety and Operations guidelines.

Research projects involving the use of aircraft include observation, tracking, and taking of 

various animals that cause agricultural crop losses or threats to human health or safety. 

Operations involving the capture of animals generally include the use of net or tranquilizer guns 

to immobilize specific animals for use in research studies. 

Fixed-wing aircraft are used primarily over open, flat, or gently rolling terrain and at lower 

elevations. Helicopters, because of better maneuverability, have greater utility and are safer over 

brushy ground, timbered areas, or broken land and mountainous areas where animals are more 

difficult to see. Flight operations are conducted close to ground level and at low airspeeds. 

Flight crews consist of a pilot and a gunner. Firearms commonly used are shotguns firing 

shotshell ammunition. Limitations due to weather, terrain, density altitude, vegetative cover, and 

related safety restrictions may limit the use of this highly selective method.

Use-pattern data indicates that this method is used throughout the year, but use is greatest during 

the fall, winter, and spring. APHIS WS reported 6,000 aerial hunting and hazing operations in 

excess of 17,000 flight hours in 1988.

(b) Hazards

Human Health and Safety

Human health and safety hazards associated with aerial hunting are related to low-level aircraft 

operations and the use of firearms. Hazards to the flight crew include: crashes due to 

mechanical failure, environmental conditions, or pilot error; shoulder bruises from firearm recoil; 

hearing loss from sustained exposure to noise of aircraft and repetitive firearm discharge; eye 

damage from discharged ammunition debris; physical injury from firearm or ammunition failure; 

and self-inflicted gunshot due to improper firearm handling.

Hazards to non-APHIS WS personnel are minimal and are limited to flight activities at and near 

airports and inhabited areas.

Environmental

Environmental hazards associated with shooting are minimal, as this method is highly selective 

for specific target animals. Hazards to nontargets are confined to animals that may be 

mistakenly identified or those which inadvertently enter the path of fire during harassment 
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activities. Localized environmental hazards associated with aircraft crashes include fires and 

fuel spills.

(c) Risks

Human Health and Safety

Risk of human injury from aerial hunting and hazing is restricted primarily to APHIS WS 

employees and contract pilots. Limiting flight operations to primarily rural environments 

essentially eliminates public exposure and thereby minimizes any risks to the public. No injuries 

to APHIS WS personnel, contract pilots, or the public were reported as a result of APHIS WS 

program use of aircraft in 6,000 aerial hunting and hazing operations in 1988. In 1998, WS 

commissioned an independent review of its aerial hunting operations. The panel made several 

recommendations and WS implemented most all of them by 2001. There were 11 fixed-wing 

and 7 helicopter accidents between 1996 and 2004. USDA (2005) discussed a subsequent 

review of aerial hunting activities and determined that the accident rate for WS was within the 

norms of aviation and have not involved the general public. Risks are considered and expected 

to remain low (USDA 2005).

Mandatory training requirements, safety standards and procedures, certification requirements, 

and strict maintenance schedules are applied uniformly to ensure the safety of flight crews and 

flight operations. When contract services are involved, the aircraft and pilot must meet rigid 

requirements before they are certified to begin operations. All aircraft are maintained regularly. 

Employees and contract pilots are closely monitored to ensure that their abilities are not impaired 

and that they do not deviate from established safety standards.

Flight crew members are required to wear protective eye, ear, and head gear, including fire 

retardant clothing. Firearms handling and use restrictions are employed to minimize risks to the 

aircraft, fellow crew members, or the public. Flight operations may be suspended by either crew 

member due to bad weather, aircraft malfunction, or other reasons which may affect the safety of 

the flight. Aerial hunting is not conducted near human habitations or other human activities.

Environmental

Environmental risks are primarily limited to animals similar in size and appearance to target 

animals. Environmental risks are minimized through training of APHIS WS personnel in species 

identification to ensure that shooting from aircraft is a highly selective damage control method. 

It may be used in areas where exposure to sensitive species is likely.

In 1988 the six MIS reporting States reported a total take by aerial hunting of 7,677 animals. No 

nontarget animals were taken by this method. 

No federally listed threatened or endangered species were taken by the APHIS WS program by 

aerial hunting.

C. Immobilizing/Euthanizing Agents

General Discussion

These methods of control involve drugs to sedate or euthanize target animals. They are normally 

administered via direct injection. These drugs include Ketaset, Beuthanasia-D, and Rompun. 

They were used in three States between FY 1988 and 1991 (Nebraska, New Hampshire, Texas). 
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Because they are administered in such a target-specific manner and involve direct disposal of 

euthanized animals or removal of immobilized target animals, no nontarget effects are expected. 

Similarly, immobilized animals are handled and transported in such a manner as to virtually 

eliminate the possibility of nontarget effects.

Critical Element Screening

Based on the above discussion, there is very little likelihood that these compounds could 

contribute to nontarget effects. Accordingly, they were eliminated from further consideration, 

based on the risk assessment scoring criteria presented below.

Documentation of Results

Primary Toxicity. No probable risk is expected, based on the critical element screening, because 

the formulated products are administered in a very target-specific manner.

Secondary Toxicity. No probable risk is expected because affected animals are immediately 

removed.
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Appendix D: Summary of Public Comments and Responses on the December 2013 PreDecision Environmental Assessment Wildlife Services’ Gray Wolf Damage Management in 

Washington

1) One commenter suggested the scope of the EA should be changed based on USFWS proposing to 

delist wolves in the remainder of WA and OR.

The proposed action in the EA included the possibility that wolves would be federally delisted and if 

so, they would be managed per the WCMPW and thus included in the proposed action. Section 1.3 of 

the EA states, “If wolves are removed from the federal ESA outside the NRMDPS, they would be 

managed by WDFW under the WCMPW. Thus any actions allowed by the WCMPW, as amended, 

would apply to wolves throughout the state. While no packs have become established in the Southern 

Cascades and Northwest Coast, expansion into the western third of Washington is anticipated.” WS 

consulted with USFWS for program effects on all federally protected species throughout the state. 

2) Several commenters offered support for WS conducting non-lethal and/or lethal control in order to 

assist WDFW with building public tolerance, reducing wolf-livestock damage, and 

recovering/conserving wolves in Washington.

Thank you for these comments and support of the Proposed Action Alternative. Sections 4.1.2, 4.2.2, 

and 4.3.2 address impacts to non-targets under the 3 alternatives. No change in the status quo to nontargets, whether WDFW or WS conducts the trapping/removal, is expected. 

Under the Proposed Action Alternative, WS would continue to evaluate practical non-lethal strategies 

for reducing wolf depredations to livestock. 

3) Three commenters referred to the potential for WS control actions to jeopardize public safety, 

sounds of gunfire in wilderness areas, and that WS provided no data involving wolves jeopardizing 

human safety.

WS follows the Fish and Wildlife Act (section 742j-1) "Airborne Hunting" (section 1.9.2 of the EA). 

Human safety was considered and discussed in section 4.3.2 of the EA. Section 2.3 of the EA states, 

“On federal public lands, planned activities must be included in work plans developed 

in coordination with each National Forest or BLM Resource Area, or in emergency, 

unplanned situations, in consultation with the respective USFS or BLM office”. 

Appendix B provides the MOU between WS and USFS, identifying the cooperation 

between the agencies in regards to WS actions on USFS lands. Therefore public 

safety would be maintained through coordination with the USFS. WS is unaware of any 

harm to public health or safety associated with agency implementation of wolf damage management 

methods in other states.

Sections 1.1 and 1.2 discuss that wolf control may also be conducted to protect the public "in the 

unlikely event that wolves threatened public safety [50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) 

(1993)]". WS agrees that it is unlikely that wolves would jeopardize public safety. There was one 

deadly wolf attack in Saskatchewan in 2005 and another in Alaska in 2010. There are multiple reports 

of non-fatal attacks (a Minnesota teenager was bitten on his head, leaving a 4.3-inch gash), mostly 

outside of the Lower 48 states.

4) Some commenters preferred Alternative 1 (No Action). 

The purpose of the proposed action is to reduce livestock depredation by gray wolves in Washington. 

Additionally, the purpose of this proposal is to be available to assist WDFW, USFWS, sovereign tribal 

governments, or the public in the unlikely event that wolves threatened public safety [50 C.F.R. §§ 

17.21(c)(3), .21(c)(4), .31(a) (1993)]. Alternative 1 was analyzed and determined ineffective for 
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providing the requested assistance to WDFW and USFWS and possible requests from Tribes for wolf 

recovery and conservation in WA.

5) Several commenters opposed Alternatives 1 (No Action/Current Program) and 3 (the Proposed 

Action Alternative), believing that WS involvement would significantly increase the number of 

wolves killed by the government and thereby jeopardize the survival of and retard the recovery of 

wolves in WA.

The EA demonstrates that WS would not remove any wolves that would not otherwise be removed by 

wolf management agencies (i.e., USFWS, WDFW, or Tribes, Section 1.3). Sections 4.1.2, 4.2.2, and 

4.3.2 address impacts to wolves under the 3 alternatives. No change in the status quo to wolves is 

expected under alternatives 1 or 3. Under both alternatives, an entity (WDFW, USFWS, Tribes, or 

WS) would conduct similar trapping/removal activities and are expected to take the similar number of 

wolves. The decision to be made is not whether or how many wolves should or should not be 

captured/removed, WDFW and the tribes have that authority. Rather this EA considers whether and 

how WS could respond to requests for assistance from WDFW, USFWS, and tribal governments. If 

WS did not respond, WS expects that WDFW, USFWS, and tribal governments would take the same 

actions without WS' assistance. WDFW is the management agency responsible for wolves in the nonlisted areas of WA. They are the entity that determines whether wolves will be trapped, removed, or 

collared. This determination and subsequent actions were analyzed in WDFW’s FEIS. USFWS is 

responsible for wolf management where wolves are federally listed and tribes are responsible for wolf 

management on all sovereign tribal lands. 

6) Several commenters were opposed to lethal removal of wolves on wilderness/public lands, believed 

that the EA failed to analyze restricting WS actions to only private lands, and wolf depredation on 

public lands are minor when compared to other losses and should be an expected cost of doing 

business.

These issues are related and collectively discussed in the EA under sections 1.2, 1.4, 2.1, 2.2, 3.2, 

4.1.1, 4.1.4, and 4.3. 

The requirement for nonlethal actions to be implemented and shown to have failed prior to WDFW 

authorizing lethal removal of depredating wolves were discussed throughout the EA. Chapter 1, 

Recent Legal Status Changes states “The requester will document unsuccessful attempts to solve the 

situation through non-lethal means. WDFW’s FEIS clarifies that, "Lethal removal may be used to stop 

repeated depredation if it is documented that livestock have clearly been killed by wolves, non-lethal 

methods have been tried but failed to resolve the conflict, depredations are likely to continue, and there 

is no evidence of intentional feeding or unnatural attraction of wolves by the livestock owner. 

Situations would have to be evaluated on a case-specific basis, with management decisions based on 

pack history and size, pattern of depredations, number of livestock killed, state listed status of wolves, 

extent of proactive management measures being used on the property, and other considerations. If it is 

determined that lethal removal is necessary, it would likely be used incrementally, as has been done in 

other states, with one or two offending animals removed initially. If depredations continue, additional 

animals may be removed". The EA, near the bottom of page 19, refers to these facts as part of the 

status quo: that WDFW or its agents may apply lethal control. Therefore, ample consideration of nonlethal methods would be made prior to using lethal removal to deal with wolf conflicts. 

The EA did not consider an alternative that would analyze the restriction of control efforts to private 

lands only because WS has no basis for making that distinction. In accordance with state/federal 

regulations, WDFW, USFWS, and Tribes are the management agencies that have the authority to 

determine whether a wolf should or should not be removed in response to wolf depredations on 

livestock, whether or not those depredations occur on public or private lands. Actions outlined in the 

EA apply to wolves depredating private livestock on private lands as well as public lands. These 

actions are supported by the WCMPW and WDFW’s FEIS. WDFW is authorized to manage wolves 

where they are federally-delisted, whether on public or private lands, and may respond to requests 

from USFWS in areas where wolves are listed. Tribes have the authority to determine wolf removal 

on their lands. WS has no authority to determine where a wolf shall be removed. The decision to be 
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made in this EA is whether WS should provide the requested assistance or leave WDFW, USFWS, and 

Tribes to take the same actions without WS' assistance.

The introduction of the EA (page 1) states, “Although livestock losses to wolves are minimal industrywide, losses to individual operators can be significant (Fritts et al. 1992, Mack et al. 1992).” Section 

1.2 of the EA points out that confirmed loss underestimate probable losses. WDFW has determined 

that wolf damage to livestock is sufficiently problematic in Washington to create the need for action, 

and it believes the need for action is expected to grow as wolves continue to become established in the 

state. The economic impact of wolf depredation on livestock can be substantial for individual 

producers. Further, when wolves come into contact with people or kill or injure their pets, there is an 

economic and an emotional loss (Linnell et al. 2002). 

7) One commenter requested us to describe WS’ interaction on USFWS Refuges and Military Land 

that allow cattle or may have wolf issues that may lead to WS to perform necessary wolf work on 

these Federal lands. 

The Proposed Action Alternative pertains to all lands within Washington State, (Section 1.3 of the 

EA). Management actions taken by WS on USFWS refuges and/or military land would only be 

conducted if a request for assistance is received from the agency responsible for managing the land in 

question. WS is not currently aware of any wolf-related or grazing-related issues on USFWS refuges or 

military lands in WA. 

8) Some comments pertained to cumulative impacts and ecological benefits from and effects to wolves 

from actions within and external to Washington. 

The EA contains discussion of wolf dispersals and movement beyond WA (Section 4.1.1). Cumulative 

effects were addressed in the EA under Section 4.3.1. Rationale for why these issues were not 

discussed in detail was provided in the EA under Section 3.2, under Issues Not Analyzed in Detail. 

After reviewing much of the information available (i.e., citations in this EA and additional researched 

materials), WS concluded that 

Wolf removal during damage management actions, combined with other forms of 

mortality, would not result in a negative effect to wolves in WA, because if WS did 

not remove the wolf, WDFW would conduct the removal or contract with a private 

party to conduct the removal. Wolf removal as a mechanism of wolf damage 

management is expected to support wolf conservation and management as discussed 

in the WCMPW (Wiles et al. 2011).

Targeted lethal wildlife damage management actions are taken with the goal of removing only the 

offending individual(s), not reducing abundance. WS would only respond to WDFW’s request to 

remove offending wolves involved in chronic depredation.

Wolf management guidelines and approaches were established by WDFW, through their FEIS and 

WCMPW. Appendices G and H of the FEIS, which WS referred the reader to throughout the EA, 

incorporate data and actions from outlying states in Population Viability Analyses and modelling 

conducted by Washington State University. The determination to be made is whether WS' actions 

would result in differences from Agencies/Tribes taking those actions. Because WDFW would remove 

wolves with the same tools available to WS and WDFW would remove the same number of wolves,

WS determined there would be no significant effect to the human environment when compared with 

the no action alternative. 

WS consulted with the USFWS to discuss whether the proposed action could affect federally protected 

endangered wolves. Section 4, page 56 addresses our Section 7 consultation, which clarifies that WS' 

actions are not expected to jeopardize Threatened or Endangered species.

a. Additional comments under this topic included “Allow nature to restore itself to balance 

through its own [checks] and balances, Wolf populations would self-regulate, Disrupts pack 

social structure, and Fails to acknowledge the serious negative effects of killing large 

numbers of wolves or the positive ecological effects associated with wolf recovery”.
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Alternative 2 was to eliminate WS from assisting in all forms of wolf management, which would be 

letting nature balance and self-regulate. This alternative would not meet goals and objectives for wolf 

conservation in WA. WDFW (Appendix A of the EA) could and would continue to lethally remove 

chronically depredating wolves whether WS assists or not. Tribes can continue to take any 

management action towards wolves they determine. 

Section 3.2 of the EA, Issues Not Analyzed in Detail, with Rationale, discussed effects of wolf removal 

on a pack structure and ecological effects of wolf removals and found “no reason to expect that wolf 

removals by WS would result in significant adverse effects on the quality of the human environment 

because of possible wolf-related changes in ecosystems”.

b. One commenter believed that “Because wolf populations must reach a certain density before 

wolves will begin to disperse out of the state, the EA and WDFW cannot count on this 

dispersal to make up for lethal removals in WA”.

Even though WS has removed wolves in other states, at the request of state and federal management 

agencies, wolf populations in those states continued to expand and increase (EA Chapter 1, 

Introduction), Bradley (2004), USDA (2011a), and USDA (2011b), in fact, well beyond original 

population goals set for recovery. There is no reason to believe that similar wolf damage management 

actions in Washington would lead to different results. Wolf management guidelines and approaches 

were established by WDFW, through their FEIS and WCMPW. Appendices G and H of WDFW’s 

FEIS, which WS referred the reader to in the EA, incorporate data and actions from outlying states in 

Population Viability Analyses and modelling conducted by Washington State University. The 

determination to be made is whether WS' actions would result in differences from Agencies and Tribes 

taking those actions in the No Action alternative. Because WDFW and Tribes could remove wolves 

with the same tools available to WS and WS would only remove the number of (or fewer) wolves 

authorized by WDFW and Tribes, (which they could/would do on their own) WS determined there 

would be no significant effect to the human environment. 

9) Some comments pertained to a lack of trust in or dislike of WS.

a. WS depredation reports provide inadequate evidence to support whether wolves are the 

probable or confirmed cause of livestock depredations. Because of the client relationship 

between livestock producers and WS there is often pressure placed upon investigators to 

make erroneous findings.

WDFW and USFWS asked WS to provide assistance in conducting wolf depredation investigations. 

Under the Proposed Action Alternative, WS would follow WDFW's Procedure for Investigation of 

Livestock Injuries & Mortalities: A Manual for WDFW Field Personnel. WS would partner with 

WDFW, USFWS, and Tribes, who would also fund WS wolf management actions. 

It is often possible that sufficient evidence may not be available to determine whether wolves are a 

probable or confirmed cause of a livestock depredation. When that is the case, WS can only provide 

the information available. If the available information is insufficient to confirm chronic wolf 

depredation, lethal removal would not be authorized under the WCMPW. WS is not the regulatory 

agency to determine whether lethal removal should be applied. The decision to resort to lethal take

rests with WDFW and Tribes.

As to the belief that WS' involvement in wolf recovery is biased, Stone (2009) noted that Defenders of 

Wildlife's compensations program...relies on the assistance of the USDA-WS to professionally 

investigate claims of losses and accurately report their findings. Bangs et al. (2006) stressed that 

compensation programs, such as Defenders', are possible because of the existence of a WS field 

program that already professionally investigates, confirms, and documents all causes of predator 

damage to livestock. Further, Stone (2009) confirmed that livestock depredation investigations 

resulted in "probable" 102 times between 1987 and 2009. Not every WS report finding is confirmed as 

a wolf depredation. Idaho Department of Fish and Game relies on WS' expertise and professionalism. 

Nadeau (2008) testified that WS conducted 92 investigations and confirmed 46 cases of wolves killing 
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livestock in 2005, 117 investigations and confirmed 54 in 2006, and 128 investigations and confirmed 

74 in 2007. In WA, WS has conducted two livestock depredation investigations, where wolves were 

suspected, with WDFW personnel. One investigation was surmised to be a pair of coyotes 

chasing/attacking sheep in SE Washington and the other was a probable wolf depredation of cattle, 

involving multiple wolves. Both investigations occurred prior to any formal reporting process with 

WDFW and both provided valuable information to WDFW. WS WA has not submitted any reports to 

WDFW that could be inadequate (as suggested by the commenter). 

b. Desist from these actions. Shut down WS. WDFW would do a better job of implementing 

the WCMP than would WS agents that bring unnecessary negative political baggage with 

them to an already controversial wildlife issue.

An "Eliminate the Current Wolf Assistance Program" alternative (Alternative 2) was analyzed and 

determined ineffective for meeting the purpose and need as specified in the EA (refer to section 4.2 of 

the EA). WDFW’s ability to implement the WCMP without WS and without further WS assistance 

was discussed under alternatives 2 and 1 respectively. 

State and federal agencies, municipalities, and the general public rely on WS for its expertise in 

resolving wildlife damage conflicts and in the research and development of new methodologies. 

Specifically regarding wolf management, the USFWS, state wildlife agencies, and private individuals 

in states where wolves currently exist cooperate with and rely extensively upon WS for its 

professionalism and expertise in providing assistance with wolf damage management. WS is wellqualified to carry out these activities. 

c. Fear that the proposed action will lead to WS having full decision making authority over 

lethal removal. WS and WDFW should conduct livestock depredation investigations jointly 

and WDFW should retain responsibility for decisions and actions regarding lethal removal. 

(Checks and balances)

State law (RCW 77.15.120) prohibits the killing of an endangered species unless it has been authorized 

by rule of the commission. Authority for the “take” of wildlife exists with the director of WDFW under 

state law RCW 77.12.240. Under RCW 77.36.030, the conditions set by the commission must include 

“appropriate protection for threatened or endangered species.” It also states that in establishing the 

limitations and conditions related to wolves, the commission “shall take into consideration the 

recommendations of the Washington state wolf conservation and management plan.” Under WAC 

232-36-051, it is unlawful to kill state endangered species causing damage to commercial livestock 

unless authorized by commission rule or WDFW permit.

Per WDFW’s FEIS and this EA, WDFW has sole authority in the decision of when to conduct lethal 

removal of wolves under its management. WS would not make that decision. WS would assist 

WDFW with livestock depredation investigations at the request of WDFW, and would not conduct 

lethal removal unless requested and authorized, as discussed on pages 3, 4, 8, 21, 27, 41, 54, and 58 of 

the EA. WS would conduct actions at the request of WDFW, who would also fund those actions. 

WDFW may conduct investigations in combination with, prior to, after, or without WS. Results from 

all investigations would be given to WDFW for review and final determination. WDFW’s FEIS

clearly identifies that non-lethal methods must be employed prior to WDFW permitting the use of 

lethal removal. 

d. Illegal attempts to kill federally-endangered wolves in Oregon in 2010 without fulfilling 

National Environmental Policy Act duties, questionable handling of livestock depredation 

investigations in eastern Oregon and Washington in the recent past, and Wildlife Services’ 

involvement as hired consultants in the killing of the Wedge Pack makes clear to us that 

Wildlife Services cannot serve an unbiased role in wolf management in Washington – or 

anywhere – and that its involvement thus far has greatly undermined gray wolf recovery 

throughout its historic range.
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WS disagrees with this statement. The commenter's claim that WS participated in illegal attempts to 

kill federally endangered wolves in Oregon in 2010 is false, has no bearing on the decision to be made 

here, and is outside the scope of analysis for this EA. WS’s involvement in assisting WDFW with the 

Wedge pack occurred at the request of WDFW after the decision to remove wolves had already been 

made, consistent with the State’s WCMPW and WDFW protocols. WDFW sought only technical 

assistance and expertise, and WS had no role in making the decision to remove wolves from this site. 

As discussed throughout the EA, the responsible wildlife management agency (WDFW, USWFS) or 

sovereign tribal government would make determinations on wolf removal, not WS. 

WS also disagrees with the comment that it is biased and its involvement has undermined wolf 

recovery in other states. Even though WS has removed wolves in other states, at the request of state 

and federal management agencies, wolf populations in those states continued to expand and increase 

[EA Chapter 1, Introduction, Bradley (2004), USDA (2011a) and USDA (2011b)], in fact, well beyond 

original population goals set for recovery. Stone (2009) noted that the Defenders of Wildlife's 

compensation program...relies on the assistance of the USDA-WS to professionally investigate claims 

of losses and accurately report their findings. Bangs et al. (2006) stressed that compensation programs, 

such as Defenders', are possible because of the existence of a WS field program that already 

professionally investigates, confirms, and documents all causes of predator damage to livestock. Stone 

(2009) further stated that WS livestock depredation investigations resulted in a finding of "probable" in 

102 investigations conducted between 1987 and 2009, rather than a finding of “confirmed” in every 

investigation. The Idaho Department of Fish and Game also relies on WS' expertise and 

professionalism in providing comprehensive and unbiased investigations. Nadeau (2008) testified that 

WS conducted 92 investigations and confirmed 46 cases of wolves killing livestock in 2005; conducted 

117 investigations and confirmed 54 in 2006; and conducted 128 investigations and confirmed 74 in 

2007. 

e. The EA assumes that WDFW will document unsuccessful attempts at using non-lethal 

management, but since that is subject to change, WS should follow a protocol that includes 

an independent analysis of the implementation and effectiveness of non-lethal methods. 

Protocol should mirror WCMPW.

The EA (pages 19, 27, and 28) identifies that non-lethal methods must be employed and documented to 

have failed prior to WDFW permitting the use of lethal removal. Documentation is WDFW’s 

responsibility as determined in WDFW’s FEIS. In addition, WDFW has a standardized protocol for 

Lethal Removal of Gray Wolves in Washington During Recovery that incorporates a Wolf Damage 

Management Flowchart requiring the investigator to confirm whether non-lethal measures were in 

place, their effectiveness, and if there are any additional, practical non-lethal measures that could be 

applied. As stated in the EA, WS actions would also be in accordance with “the WCMPW or similar 

guidance (e.g., ESA and CFR)”. WS has been granted the authority and expertise under the Act of 

March 2, 1931 (46 Stat. 1468; 7 U.S.C. 426–426b), as amended, and the Act of December 22, 1987 

(101 Stat. 1329-331, 7 U.S.C. 426c) to provide wildlife damage management services. This includes 

maintaining technical expertise in the science of WDM control tools and techniques, conducting 

wildlife damage management research, conducting management programs, conducting wildlife disease 

surveillance, and complying with NEPA requirements for wildlife damage management. WDFW has 

the regulatory authority to manage federally de-listed wolves in WA and may assist USFWS when 

requested by USFWS. These agencies have the federal/state authority and expertise to make 

determinations without the need for further independent analysis of the implementation and 

effectiveness of non-lethal methods. 

10) Some comments suggested we keep gray wolves on the ESA, some said they should be removed from the 

ESA, and one referred to issues regarding Mexican wolves.

This issue about Mexican wolves is outside the scope of this EA and WS has no regulatory authority to 

list or delist any species under the ESA. The decision to delist federal species is the responsibility of 

the USFWS. The decision to delist state species is the responsibility of each state.
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11) Some comments questioned whether removing depredating wolves aided in building public 

tolerance/conservation benefits for wolves

Rapid, effective assistance to human-wolf conflicts is critical to maintaining support for wolf 

populations, not just among affected stakeholder groups but the public in general (Bath 1987, 

McNaught 1987, Pate et al. 1996, Mech 1995, Wolstenholme 1996, Bjerke et al. 1998, Naughton et al. 

2005, Bruskotter et al. 2010, 74 FR 15123). USFWS and state wildlife agencies have relied on lethal 

removal for maintaining/increasing public tolerance for wolves throughout all areas where wolves are 

recovering. There is no reason to suspect that Washington State would be any different. 

Human tolerance has been and remains the primary limiting factor for wolf survival and non-lethal and 

lethal control activities actually may promote the long-term survival of the wolf by enhancing 

tolerance. The Wolf Conservation and Management Plan for Washington (WCMPW, Wiles et al. 

2011) states that to build public tolerance for wolves, the WCMPW outlines a range of proactive, nonlethal options, and lethal management options for addressing wolf-livestock conflicts. Implementation 

of these would be based on the status of wolves to ensure that recovery objectives are met. Non-lethal 

management will be emphasized while the species is recovering and will transition to a broader range 

of approaches as wolves progress toward a delisted status. The 1980 and 1987 NRM wolf recovery 

plans (USFWS 1980, 1987) and wolf control plans (USFWS 1988, 1990) recognize that conflict with 

livestock was the reason that wolves were extirpated, and the reduction of conflicts is a necessary 

component of wolf recovery. These plans and others also acknowledged that control of problem 

wolves is important to maintain local public tolerance of wolves and that removal of some wolves did 

not prevent the wolf population from achieving recovery (Bath 1987, McNaught 1987, Fritts 1993, 

Pate et al. 1996, Mech 1995, Bangs et al. 1995, Wolstenholme 1996, Bjerke et al. 1998, Fritts et al. 

2003, Bangs et al. 2009, Creel and Rotella 2010, Bruskotter et al. 2010, 74 FR 15123). 

In her chapter on compensation and nonlethal control in New Era for Wolves and People, Stone (2009) 

explained that "Not every situation will be resolved using non-lethal methods... Success at maintaining 

and restoring healthy wolf populations across the American West and elsewhere will be directly 

comparative to reducing conflict..."

12) Several commenters shared the belief that wolves should not be killed.

This issue was discussed in sections 1.4, 2.2, 4.1.1 and 4.3 of the EA. The decision to lethally remove 

wolves would be made by WDFW, USFWS, or sovereign tribes, not by WS. The decision to be made 

in this EA is whether WS should provide the requested assistance or leave WDFW, USFWS, and 

Tribes to take the same actions without WS' assistance. As stated in the EA under Section 2.1, 

Lethal removal may be used to stop repeated depredation if it is documented 

that livestock have clearly been killed by wolves, non-lethal methods have been 

tried but failed to resolve the conflict, depredations are likely to continue, and 

there is no evidence of intentional feeding or unnatural attraction of wolves by 

the livestock owner.

WDFW’s FEIS further outlines that:

Situations would have to be evaluated on a case-specific basis, with 

management decisions based on pack history and size, pattern of depredations, 

number of livestock killed, state listed status of wolves, extent of proactive 

management measures being used on the property, and other considerations. If 

it is determined that lethal removal is necessary, it would likely be used 

incrementally, as has been done in other states, with one or two offending 

animals removed initially. If depredations continue, additional animals may be 

removed.

WDFW is authorized to manage wolves where they are federally-delisted and may respond to requests 

from USFWS in areas where wolves are listed. In accordance with state/federal regulations, WDFW, 

USFWS, and tribal governments are the entities that have the authority to determine whether a wolf 

should or should not be removed. WS has no authority to make that determination. 

See response to 11 also. 
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13) Several of the comments pertained to how methods could be used, that some methods should not be used, 

and that not enough information about the methods was given. 

a. WS does not address if it will use dogs in its operations, how they will be used, and what 

protections will ensure control. Dogs were called at least twice during the wedge wolf killings 

in which WS was a consultant.

Sections 2.1, 2.2., and 2.3 address the methods WS could use under each alternative. Sections 4.1.2 

and 4.3.2 referred the reader to USDA 1997 (Appendix P), which includes the use of dogs (including 

dogs as decoys). Pertinent discussions from Appendix P were added to the EA as Appendix C. The 

EA is a stand-alone document, thus readers will not need to refer to USDA 1997, Appendix P. WS 

WA may, but does not expect to use dogs extensively in wolf removal actions. However, decoy dogs 

are a legal and effective tool in predator management.

WS WA solely provided technical assistance and did not take direct control actions during the 

referenced wolf removal. 

b. EA downplays value of animal husbandry and ignores studies that it is an effective longterm deterrent. Musiana (2005) found that "we see the greatest promise for reducing wolf 

depredation by improving animal husbandry."

The EA does not downplay the value of animal husbandry or effective non-lethal methods. The EA 

and WCMPW clearly stipulate that lethal removal would not be conducted unless non-lethal methods 

were attempted and failed (Chapter 2 of the EA). 

c. I most certainly do not want any wolves to be radio-collared if that technology will be used to 

destroy wolves.

Telemetry is a proven method for effectively and efficiently assisting in the management of 

depredating and non-depredating wolves and in differentiating between the two. Section 4.1.4 of the 

EA discusses that guardian personnel can be more effective if they make use of telemetry devices to 

detect nearby wolves. WS recognizes that some members of the public do not believe that wolves 

should ever be killed, regardless of the means. However, management agencies strive to utilize the 

best management methods available to assist in the management and conservation of wolves in WA. If 

a pack of depredating wolves has a radio-collared wolf in it, and WDFW determined that a wolf or 

wolves from that pack should be removed, using telemetry to locate and efficiently remove the 

authorized wolves could reduce exposure to other species, reduce further depredations quicker, and 

better increase public tolerance for wolves. 

d. The EA must identify the make and model of leghold traps and analyze the impact on wolves 

and non-target spp.

Chapters 2 and 4 addressed traps and other methods WS proposed to use under each alternative and the 

effects that these traps and other methods would have on the quality of the human environment. WS 

would use the most effective, safe, and humane tools currently available and could incorporate new 

tools entering the marketplace that provide added benefit. Impacts to wolves and non-target animals 

were thoroughly discussed in the EA. 

e. This EA does not provide enough information regarding lethal methods.

A thorough description of lethal methods available to WDFW and WS under the proposed alternative 

is given in section 2.3 of the EA. Pages 30 through 36 identify measures used by WS to minimize 

environmental risk when applying those methods.

f. WS did not identify any requirement to check traps in a timely fashion.

Washington State law requires all foothold traps and foot snares to be checked every 24 hours (pages

23-24 of the EA), and WS would monitor foothold traps or snares every 24 hours while using them

(page 30 of the EA).
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g. Public sentiment in WA continues to strongly oppose trapping, unlike other regions of our 

country that have wolf populations under state management that are hunted and trapped. 

As stated in Section 1.9 of the EA, “WS cooperates with land and wildlife management agencies to 

resolve wildlife damage problems in compliance with applicable federal, state and local laws”. The 

use of traps is legal in Washington. The commenter is likely referring to provisions in state law 

resulting from Washington State Voters’ Initiative 713 (I-713) which passed in 2000. I-713 and 

Washington state law recognize the importance of trapping as a wildlife management tool, to include 

trapping of problem/dangerous wildlife. The Washington State Director of Wildlife is authorized to

grant special permits to use traps in responding to animal problems that have not and cannot be 

reasonably abated by the use of non-lethal control tools. Further, the Director may grant special 

permits to department employees or agents where the use of the traps is the only practical means of 

protecting threatened or endangered species (RCW 77.08.010). 

However, this issue has no effects on the status quo, whether WS, WDFW, or Tribes conducts the 

removal that WDFW and Tribes have the authority to determine and authorize. The decision to be 

made is whether WS should provide the assistance when requested or not. 

14) Some commenters cited published literature to suggest that removal of wolves does not reduce 

depredation. They believe that the only solution is to reduce the vulnerability of livestock using 

improved animal husbandry and non-lethal tools. They cited the following:

- Harper et al (2008) found that "no analysis indicated that trapping wolves substantially 

reduced the following year's depredations at state or local levels". 

- ...because new wolves will typically disperse into the habitat vacated by prior wolves and 

unless new deterrents are in place, leading to perpetual livestock and wolf losses (Musiani 

2005). 

- ...subsequent depredations indicate that lethal removal is only temporarily effective 

(Bradley 2004). 

There are cases where wolves co-exist with livestock and wolf depredation does not result. As cited on 

Page 49 of the EA, "Bradley (2004) found that after partial or complete wolf pack removal, 

depredations usually ceased for the remainder of the given grazing season". Breck et al. (2012) 

reported that research must be framed with realistic expectations. The most important of which is that, 

even under ideal conditions, where wolves and livestock coexist on the landscape wolves will likely 

kill livestock, and as a result, some wolves will likely be removed. This is particularly true for 

developing and testing of nonlethal tools, where often, the unrealistic expectation is to find techniques 

that permanently stop wolves from killing livestock without resorting to lethal control. Paul (2005) 

found that when removing problem wolves that killed domestic animals, the USDA-WS wolf 

depredation control program helped to resolve localized wolf damage situations, and thus ultimately 

facilitated wolf recovery by building public tolerance of wolves. Bangs and Shivik (2001) warned that 

because some non-lethal tools are very effective in certain situations, some managers and especially 

members of the general public are easily mislead into believing that one method, such as electric 

fencing, guard animals (Meadows and Knowlton 2000), or scare devices (Koehler et al. 1990) are the 

solution to all livestock depredation problems, and this is not the case. 

The commenter’s citation of Harper et al. (2008) is incomplete and out of context. The remainder of 

the quote reads: "However, more specific analyses indicated that in certain situations, killing wolves 

was more effective than no action (i.e., not trapping). For example, trapping and killing adult males 

decreased the re-depredation risk." In her chapter on compensation and nonlethal control in New Era 

for Wolves and People, Stone (2009) explained that "Not every situation will be resolved using nonlethal methods... Success at maintaining and restoring healthy wolf populations across the American 

West and elsewhere will be directly comparative to reducing conflict..."
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15) The following comments pertained to readers perceiving that the issue addressed by the EA was 

controversial, there would be significant impacts, the impacts would be greater than suggested by WS, 

and that an EIS was required:

a. Because so many of the NEPA significance factors are present (including degree to which the 

proposed action affects public health or safety; adverse effect on cultural resources; highly 

controversial nature of the proposal; highly uncertain or unknown risks of the proposal; 

cumulatively significant impacts when Wildlife Services wolf management in other states is 

considered; adverse effects on federally-listed species; and potential violation of Federal, 

State, or local law), Wildlife Services must prepare an EIS.

WS analyzed these issues in the EA and found that none had significant impacts. CEQ regulations 

implementing NEPA explains that the term “significantly” requires consideration of the context and 

intensity of the actions (40 CFR Sec. 1508.27). The EA provides ample evidence that no significant 

effects are likely, and the FONSI considered all of the points of potential significance. In considering 

the context of the action, any actions WS would take to implement the proposed action must fall within 

the criteria spelled out under state law (RCW77.12.240) and the state wolf plan (WCMPW) (EA 

Introduction, Sections 1.1, 1.3, 1.4, 1.5, and 1.6). The EA shows that any action taken by WS to 

manage wolf damage would occur whether or not WS decided to implement the proposed action. The 

intensity of the actions was also considered in the NEPA process. Specific issues that were determined 

to be important for analysis in the EA included the beneficial and adverse effects on the wolf 

population, the degree to which the proposed action may affect public safety, cumulative effects, 

effects on ESA listed species, and compliance with Federal, state, and local laws, among other issues.

Section 3.2 lists aspects of the human environment that would not be affected and why. Sections 1.9.2 

and 3.2 describe why there would be no adverse effects on cultural resources and Section 1.7 discusses 

outreach to tribes. Tribes were mailed written notice of the intent to prepare this EA as well as when 

the Pre-Decisional EA was available. All Federally recognized tribes in were given information about 

the proposal and were invited to participate in the NEPA process. The FONSI has included all of the 

significance criteria listed in CEQ NEPA Implementing Regulations (40 CFR 1508.27) and explains 

why the impacts are not severe, intense or otherwise potentially significant.

We refer the reader to the following sections of the EA:

1) public health or safety (Section 4.3.2 of the EA), 

2) adverse effect on cultural resources (Section 4.3.3 of the EA), 

3) highly controversial nature of the proposal - We disagree that the nature of the effects of the 

proposal are highly controversial (Sections 4.1.3, 4.2.3, and 4.3.3). The term “controversial” has been 

interpreted as a substantial dispute over the size, nature or effects of a major federal action, not 

opposition to a proposal (Daniel R. Mandelker, NEPA Law and Litigation §8:47 (2d ed. 2009). A 

subjective difference of opinion by some individuals or groups does not constitute a sufficient degree 

of scientific controversy so as to be significant. "Opposition and a high degree of controversy . . . are 

not synonymous."6 The effects of lethal control actions are not controversial among agency 

researchers and experts involved with gray wolf management. The state and federal wildlife 

management agencies recognize the need and value of lethal removal and are the agencies requesting 

WS to conduct these actions. Lethal removal has been part of the successful recovery plan for wolves 

in the U.S. and has been demonstrated by the successful recovery of the NRM DPS. The USFWS 

plans have proven successful, and are supported among the agency experts. Lethal control of 

depredating wolves has remained compatible with recovery; wolf populations have expanded and their

distribution and numbers have exceeded predictions (USFWS 1994, USFWS et al. 2007, 2008, 2009, 

2010).

4) highly uncertain or unknown risks of the proposal – Risks are discussed and analyzed throughout 

the document. Section 2.3 deals specifically with Standard Operating Procedures developed to 

 

6

718 F.2d 29 (2d Cir. 1983). See also Foundation for Global Sustainability v. McConnell, 829 F. Supp. 147, 153 

(W.D.N.C. 1993) (holding that objections by several groups to Forest Service decision for salvage project to harvest 

timber damaged by tornadoes are not robust enough dissent to affect agency decisionmaking responsibilities).
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minimize environmental risk. In addition, the reader was referred to USDA 1997 Appendix P, which 

is a formal risk assessment of WS methods. To simplify things for the reader, WS has included 

pertinent discussions from Appendix P into the final EA in Appendix C, Risk Assessment of Potential 

Direct Control Methods Used by APHIS WS. The EA is a stand-alone document, thus readers will not 

need to refer to USDA 1997, Appendix P. 

5) cumulatively significant impacts when Wildlife Services wolf management in other states is 

considered (Introduction and Section 4.3.1 of the EA), 

6) adverse effects on federally-listed species (Section 4.3.2 of the EA), and

7) potential violation of Federal, State, or local law (Section 1.9 of the EA, “WS cooperates with land 

and wildlife management agencies to resolve wildlife damage problems in compliance with applicable 

federal, state and local laws.”).

Multiple publications identify the need for the public to tolerate wolves if wolf conservation and 

recovery is expected to succeed. Rapid, effective assistance to human-wolf conflicts is critical to 

maintaining support for wolf populations, not just among affected stakeholder groups but the public in 

general (Bath 1987, McNaught 1987, Pate et al. 1996, Mech 1995, Wolstenholme 1996, Bjerke et al. 

1998, Naughton et al. 2005, Bruskotter et al. 2010, 74 FR 15123). 

b. Lethal wolf removal has been occurring for years, and Wildlife Services needs to conduct an 

analysis on the impacts this removal has had on depredation rates. The lack of science in this 

context becomes more relevant in light of recent public criticism of Wildlife Services’ 

predator control programs by professional societies including the American Society of 

Mammologists and The Wildlife Society. 

The purpose is to reduce livestock depredation by gray wolves (rates can vary within and from state to 

state). Additionally, the purpose of this proposal is to be available to assist WDFW, USFWS, 

sovereign tribal governments, or the public in the unlikely event that wolves threatened public safety 

[50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) (1993)]. As cited on Page 49 of the EA, "Bradley (2004) 

found that after partial or complete wolf pack removal, depredations usually ceased for the remainder 

of the given grazing season". Breck et al. (2012) reported that research must be framed with realistic 

expectations. The most important of which is that, even under ideal conditions, where wolves and 

livestock coexist on the landscape wolves will likely kill livestock, and as a result, some wolves will 

likely be removed. Paul (2005) found that when removing problem wolves that killed domestic 

animals, the USDA-WS wolf depredation control program helped to resolve localized wolf damage 

situations, and thus ultimately facilitated wolf recovery by building public tolerance of wolves. Bangs 

and Shivik (2001) warned that because some non-lethal tools are very effective in certain situations, 

some managers and especially members of the general public are easily mislead into believing that one 

method, such as electric fencing, guard animals (Meadows and Knowlton 2000), or scare devices 

(Koehler et al. 1990) are the solution to all livestock depredation problems, and this is not the case. 

WS is unaware of any “recent public criticism of Wildlife Services’ predator control programs by ... 

The Wildlife Society”. In fact, in May of 2012, The Wildlife Society (TWS) released a Final Position 

Statement on Wolf Restoration and Management in the Contiguous United States. In this statement, 

TWS stated:

Wolf restoration in the Northern Rocky Mountains and Western Great Lakes 

succeeded because of connectivity between secure wolf populations, there were 

large blocks of suitable habitat that could support persistent packs, agency 

management minimized conflicts, and adequate tolerance by local residents was 

achieved. That combination of conditions is uncommon elsewhere.

We also refer the reader to Comment 11.

c. Wildlife Services' involvement in wolf control, both in Alternatives 1 and 3, would increase 

the number of wolves killed in the state. WS' federal appropriations allow it to offer belowcost rates to [WDFW], thereby allowing it to kill more wolves within limited budgets. -

As discussed in Sections 1.1 and 4.3.1, WS would only conduct wolf damage management in 

accordance with the WCMPW, CFR/ESA rules, or similar guidance (in the case of Tribes). Under the 
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WCMPW, WDFW has the authority to determine the number of wolves that will be killed. WS will 

not make this determination. Therefore, no more wolves would be killed than what WDFW, USFWS, 

or Tribes authorize, regardless of which agency takes action. 

Under the Proposed Action Alternative, no change in the status quo to wolves, based on whether 

WDFW or WS conducts the trapping/removal, is expected. WDFW is the management agency 

responsible for wolves in the non-listed areas of WA, USFWS is the management agency responsible 

for wolves where wolves are federally listed, and Tribes are the management agency on tribal lands. 

They are the entities that determine whether and how many wolves will be trapped, removed, or 

collared. This determination and subsequent actions were analyzed in the FEIS. WDFW has the same 

access to helicopters and fixed-winged aircraft as WS. Also, WDFW would fund all WS direct control 

actions they request, and WDFW would reimburse all aircraft charges. As WDFW stated in their letter 

(Appendix A of the EA) and subsequent discussion with WS, they would conduct the action if WS 

does not, and funding is expected to be sufficient to conduct lethal removal of any wolves they 

determine. 

16) Several comments were in regards to whether or not enough emphasis requiring non-lethal measures 

would be required, that non-lethal measures were down-played in the EA, that only non-lethal should be 

available, and the non-lethal must be used prior to lethal removal.

a. The EA reviews several non-lethal management tools, but ultimately concludes that they are 

only temporarily effective at best, except for increased human presence.

The EA assists WS in determining whether the Proposed Action Alternative (WS assisting in wolf 

trapping and removal at agency/tribal requests) would result in significant effects to the human 

environment. Education and nonlethal technical assistance are integral to the Proposed Action

Alternative as discussed in Chapter 1, Section 1.2, and Section 2.1. Nonlethal measures are already 

required by the WCMPW (Wiles et al. 2011.) and must be deemed ineffective prior to lethal control 

being authorized. WDFW, USFWS, and Tribes are the management agencies that have the authority to 

determine whether a wolf should or should not be removed in response to wolf depredations on 

livestock. WS has no authority or ability to make that determination. 

b. Please consider alternatives [other than lethal] to deal with wolf conflict. Nonlethal should 

be required before lethal.

This issue was addressed in sections 1.4, 2.2, 4.1.1 and 4.3 of the EA. Education and nonlethal 

technical and direct assistance are integral to the Proposed Action Alternative. Nonlethal measures are 

already required by the Wolf Conservation and Management Plan for Washington (WCMPW, Wiles et 

al. 2011.) and must be deemed ineffective prior to lethal control being authorized. WDFW, USFWS, 

and Tribes are the management agencies that have the authority to determine whether a wolf should or 

should not be removed in response to wolf depredations on livestock. WS has no authority or ability to 

make that determination. 

WDFW’s FEIS outlines that "Lethal removal may be used to stop repeated depredation if it is 

documented that livestock have clearly been killed by wolves, non-lethal methods have been tried but 

failed to resolve the conflict, depredations are likely to continue, and there is no evidence of intentional 

feeding or unnatural attraction of wolves by the livestock owner. Situations would have to be evaluated 

on a case-specific basis, with management decisions based on pack history and size, pattern of 

depredations, number of livestock killed, state listed status of wolves, extent of proactive management 

measures being used on the property, and other considerations. If it is determined that lethal removal is 

necessary, it would likely be used incrementally, as has been done in other states, with one or two 

offending animals removed initially. If depredations continue, additional animals may be removed". 

Ample consideration of non-lethal methods would be made prior to using lethal removal to deal with 

wolf conflicts. WDFW is authorized to manage wolves where they are federally-delisted and may 

respond to requests from USFWS in areas where wolves are listed. 
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c. WS criticizes nonlethal methods, yet seeks to be the one to implement them.

WS disagrees with this comment and discussed the issue in the EA under sections 1.4, 2.1, 2.2, 4.1.1, 

4.1.4, and 4.3. As stated in the Section 2.1, "...lethal removal may be used to stop repeated depredation 

if it is documented that livestock have clearly been killed by wolves, non-lethal methods have been 

tried but failed to resolve the conflict, depredations are likely to continue, and there is no evidence of 

intentional feeding or unnatural attraction of wolves by the livestock owner”. Therefore, ample 

consideration of non-lethal methods will be made prior to using lethal removal to deal with wolf 

conflicts. 

17) Some commenters felt WS failed to properly address impacts to non-target animals and did not 

adequately consult with USFWS under Section 7 of the ESA. 

Section 2.3 of the EA addresses mitigation measures WS would have in place to reduce the likelihood 

of capturing a non-target animal during the course of its actions. Sections 4.1.2, 4.2.2, and 4.3.2 

address impacts to non-target species under the 3 alternatives and show that results of the No Action 

and Eliminate the Wolf Assistance Program alternatives would be similar to the Proposed Action

Alternative (Section 4.4). No difference to non-target species, whether WDFW or WS conducts the 

management action, is expected. 

A commenter discussed 59 lynx captured in the Northeast in traps set for other animals, but neglects to 

identify that these traps were not set by WS personnel. WS WA has not unintentionally captured a 

lynx in the last 30 years. 

Section 4, page 56 addresses WS’ Section 7 consultation, which clarifies that WS' actions are not 

expected to jeopardize Threatened or Endangered species. WS’ consultation with the USFWS on 

wolverine (Gulo gulo) was inadvertently omitted from the EA. Although the wolverine is not formally 

listed as a Federally Threatened species, it was recently proposed for such status. WS conferred with 

USFWS on wolverines in November - December 2013, stating that WS' actions "are not likely to 

destroy or adversely modify wolverine critical habitat if it were designated" and that we do not 

anticipate that the effects of our actions would negatively affect wolverine. USFWS concurred. We 

have updated the EA (section 4.3.2) to reflect consultation on wolverines. Section 4.3.2 was also 

updated to include reference to Canada lynx. See section 2, page 4 of this FONSI.

18) The following comments pertained to humaneness concerns and reporting or communication of 

activities:

a. Wildlife Services should never use any means that cause anywhere near that much pain. 

They should have to check their traps more often to. This EA does not suggest humaneness 

is chosen over expediency. 

Humaneness is an issue discussed in the EA under Sections 4.1.3, 4.2.3, and 4.3.3. Section 2, Measures 

used by WS to Minimize Environmental Risk, discusses standard operating procedures built into its 

programs which serve to minimize the potential for negative effects on the environment, including 

potential harm to humans and non-target wildlife. WS treats wolves and other wildlife as humanely as 

conditions allow and uses euthanasia methods recommended by the AVMA (2013) for free ranging 

wildlife (Julien et al. 2010). Wildlife Services Directive 1.301 (8/31/10) requires program personnel to 

“utilize the WS Decision Model (EA Section 2.3, Figure 3) to resolve wildlife damage problems and 

strive to use the most selective and humane methods available, with preference given to nonlethal 

methods when practical and effective.” WS provides technical assistance to ranchers to reduce losses,

and our preference is to prevent livestock depredations from occurring 

(http://www.aphis.usda.gov/ws/mission. html). WS trains its employees in humane wildlife handling 

techniques. WS uses traps and trapping techniques that comply with standards set by the Association 

of Fish and Wildlife Agencies (AFWA) Best Management Practices (BMP) (AFWA 2006). WS uses 

equipment and techniques to avoid the capture of nontarget wildlife, including pan-tension devices, 

when appropriate, to reduce capture of smaller non-target animals and appropriate anchoring systems 

[AFWA (2006) and Turnbull (2011)] so that larger non-target species may pull free.
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WS complies with Washington State law (RCW 77.15.194) requiring that all foot snares and foot-hold 

traps be checked every 24 hours. 

b. The only proposed monitoring is self-reporting of limited data. Does this include round 

counts, types of firearms, number of wolves injured or cubs orphaned? There is no plan for 

dependent cubs. If a wolf disappears into a den, how is it removed? Injured wildlife can 

become more dangerous on approach due to their increased vulnerability. Will injured nontarget wildlife be taken to a wildlife rehabilitation center or killed? Where is the oversight to 

ensure reporting? 

WS records control actions in its MIS database. Information gathered includes hours worked, species 

targeted, fate of targeted species, where, when, resources protected, etc. WS does not record the

number of live rounds discharged. Annual reports of WS activity are released to the public. WS has 

an internal supervisory structure under which employees report activities according to program 

policies. WS would report the results of its actions to the responsible land/resource management 

agency (WDFW, USFWS, or Tribes) requesting the service from WS Section 2.3 of the EA). 

Trapping allows for the release of non-target animals (page 23 of the EA). WS WA’s non-target take 

using the methods described in the EA has been 0.01% of the total take over the last 7 years. The EA 

identifies the measures WS uses to minimize environmental risk (page 29). This includes, "Non-target 

animals captured are released at the site of capture unless the WS personnel determine that they will 

not survive." 

Depending on the circumstances, lethal removal of wolves to address livestock depredation problems 

may involve removing some or all members of a specific wolf pack. If WDFW decides to remove the 

entire pack, concerted efforts are made to remove all of the pups as well as the adults, in order to avoid 

orphaning the pups. It is not always possible to remove all the adult wolves from a pack and in those 

cases, the remaining wolf or wolves may continue to feed and care for the remaining pups (Boyd and 

Jimenez 1994, Packard 2003). Despite concerted efforts to humanely remove any pups left after all 

adult wolves of a pack have been removed, one or more pups may be left on very rare occasions 

without any adult wolves to feed or care for them. The only way to avoid this circumstance altogether 

would be to limit wolf removal efforts during this time frame, so as to always ensure that at least one 

or more adult wolves were left to care for any pups. In some circumstances, this would be inconsistent 

with the objective of stopping chronic wolf predation on livestock. This issue does not affect the 

analysis because WS’ actions are not expected to have different results that the same actions conducted 

by WDFW, USFWS, or Tribes.

Unfortunately, there could be occasional instances where dependent young may be orphaned or a wolf 

could be injured, but unrecoverable during removal activities. To keep things in perspective, it is 

important to consider the amount of suffering and death that occurs in the absence of predator removal 

as well. Predators by definition kill and eat prey, which does not ordinarily represent a problem unless 

this behavior conflicts with human interests. But regardless of whether predation creates conflicts with 

human interests, prey species are typically subjected to pain and suffering when preyed upon by 

predators. Death in nature is notoriously harsh (Howard 1986), and it would be purely speculative to 

infer whether the fate of any potentially orphaned wolf pups would be any more or less harsh if their 

parents had not been killed through wolf management activities. 

To the extent that wolf management removes animals that would otherwise continue to kill, injure, or 

orphan prey animals, the overall level of pain and suffering may or may not be reduced.

c. WS provided technical support and consultation to WDFW in the killing of the wedge wolf 

pack. It advocated high-impact lethal controls in an area with diverse wildlife and 

recreational use. WS proposes to communicate with other agencies when it becomes the lead, 

but the EA is not specific about how formal this communication will be.
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WS has the federal expertise and authority, under the Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C. 

426-426b) as amended and the Act of December 22, 1987 (101 Stat. 1329-331, 7 U.S.C. 426c), to 

provide technical assistance to people and agencies and provided information to WDFW on trapping 

and removal methods. WS WA did not lethally remove any wolves in the wedge wolf pack, nor did

WS WA set any traps to capture wolves in this pack, as the commenter implied. The Proposed Action 

Alternative clearly states that WDFW is the lead agency where wolves are federally de-listed and 

would continue as such. USFWS is the lead agency where wolves are federally listed. Tribes are the 

lead agencies where wolves are on sovereign tribal lands. WS would formally and/or informally 

communicate with each, in their respective management areas. 

19) The following comments pertained to the legitimacy of the proposed action/purpose and need:

a. Why would Wildlife Services be used as a subsidy to farmers/ranchers? This agency is 

reacting to political pressure and false information. Most attacks on livestock can be 

attributed to feral dogs. This agency should not even exist. 

This comment is outside the scope of the EA. WS has authority under the Act of March 2, 1931 (46 

Stat. 1468; 7 U.S.C. 426-426b) as amended, and the Act of December 22, 1987 (101 Stat. 1329-331, 7 

U.S.C. 426c). WDFW/USFWS requested that WS assist in the recovery and conservation of wolves in 

Washington by conducting trapping and removal of problem wolves to reduce wolf depredation on 

livestock and increase public tolerance for wolves. WDFW would conduct wolf removal actions 

whether WS provides assistance or not (Appendix A). WDFW and USFWS requested WS assistance 

because they recognize the professionalism and ability of WS to assist with wolf-livestock conflicts. 

b. WDFW would have to divert funding from other, non-lethal management activities in order 

to address chronic depredations. Much of WDFW’s funding is earmarked for specific nonlethal activities, and this funding and personnel time cannot simply be shifted to killing 

wolves. [T]he EA is not accurate to the extent it relies on these assertions in order to justify 

Wildlife Services involvement in wolf management in Washington. The EA Fails to Disclose 

the Funding Sources for Wildlife Services’ Activities.

Currently, funding for direct control activities would be provided by the cooperator (e.g., WDFW, 

USFWS, or Tribes). WS cannot project sources of future funding (e.g., if Congress allocates funds for 

such actions). WDFW was clear, that they are authorized and plan to implement harassment and lethal 

removal in cases of chronic depredation (Appendix A of the EA).

c. Either the agency has the expertise, personnel, and equipment that would assist and make 

more efficient and effective the killing of wolves or the agency does not, and its involvement 

in Washington is unnecessary given that the State of Washington could and would conduct 

the activities anyway.

WDFW requested WS’ assistance. The decision to be made is whether WS should provide the 

requested assistance or leave WDFW, USFWS, and Tribes to take the same actions without WS' 

assistance. WDFW is the management agency responsible for wolves in the non-listed areas of WA. 

They are the entity that determines whether wolves will be trapped, removed, or collared. This 

determination and subsequent actions were analyzed in the WDFW’s FEIS. WDFW clearly stated that 

they would conduct necessary wolf removal if WS denied their request for assistance (Appendix A in 

the EA). WDFW would use the same tools and methods. WS' involvement would allow WDFW 

personnel to focus on proactive recovery and conservation activities. "We [WDFW] want to be 

working with livestock producers proactively next spring and using techniques to minimize conflicts 

rather than responding to escalating depredation events. This proactive approach should help us 

minimize the number of lethal removals necessary and hopefully completely avoid the need for the 

removal of an entire pack (Appendix A in the EA)." 

WDFW recognizes that depredations will occur. WDFW would prefer to allocate their personnel 

towards proactive prevention methods, while funding WS to conduct trapping and removal, rather than

assigning personnel to trapping and removing at the expense of limiting their time on other recovery 

and conservation methods. WS' expertise includes the entire spectrum of efficiently reducing wolf-
APPENDIX D

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 106

livestock conflicts. Wolf removal is a small, though critical, component of the overall approach to 

recovery of wolves in WA. Having a WS biologist able to respond to livestock mortality in a timely 

manner will show the public that WDFW is responsive to producer concerns, whether the mortality is 

confirmed a wolf or not. This would increase acceptance for wolves in Washington, thereby aiding 

wolf recovery and conservation. 

d. The EA’s Discussion of Economics is Not Supported by Data or Analysis. Wildlife Services 

concedes that livestock losses to wolves are “minimal” but argues that killing wolves is 

necessary to keep individual ranchers financially afloat [EA at v.].

WS was unable to find any such reference to keeping individual ranchers financially afloat. Section 

1.2 in the EA discusses the direct, indirect, and probable effects that wolves have on livestock 

production. As discussed in the EA, confirmed livestock kills do not represent total probable direct 

mortality, nor do they account for indirect damages to livestock and associated costs to producers. 

While total statewide numbers of confirmed livestock losses from wolves may be less than other 

sources of mortality, wolf depredation can create substantial hardships on affected individual 

producers.

e. Fails to establish a purpose and need.

Section 1.1 clearly identified the purpose as "to reduce livestock depredation by gray wolves in 

Washington. Additionally, the purpose of this proposal is to be available to assist WDFW, USFWS 

and sovereign tribal governments or the public in the unlikely event that wolves threatened public 

safety [50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) (1993)]." The need was clarified in Section 1.2, 

"The increasing presence of wolves in Washington initiated a need to mitigate and resolve conflicts 

when wolves cause harm to livestock. Lethal control of de-listed wolves may be necessary to resolve 

repeated wolf-livestock conflicts and would be performed to remove problem animals that jeopardize 

public tolerance for overall wolf recovery (Wiles et al. 2011)."

f. To justify this proposition [Alternative 3], Wildlife Services does not cite any data or 

scientific literature, however, but cites a declaration provided by a rancher who claimed 

losses of $7,400 from a wolf depredation. This attempt at economic analysis is misleading 

and unfounded, and raises issues of a controversy surrounding the true economic benefit of 

wolf management in Washington.

Section 1.2 of the EA discusses several costs of predation on livestock. WS makes no attempt to 

mislead the public about costs associated with wolf depredation. The sections to which the commenter 

refers relate to the need for action, which is that wolves do depredate livestock and those depredations 

and the protections livestock producers employ come at a cost to the individual livestock producer. 

Often, these costs are not fully quantifiable, and the general public may not be aware that all wolves do 

not kill cattle. There are ranches that have wolf packs overlapping their range without depredations 

occurring. 

20) The following comments pertained to suggested edits in the EA:

a. Please omit references to "two solitary wolves occur in Northeast Washington".

The sentence was clarified to read, "Two solitary wolves (e.g., not associated with known packs) are 

confirmed to occur in northeastern Washington".

b. In Chapter 3, making a reference to "no ground disturbance" is not correct. Installing traps 

requires some ground disturbance. 

The sentence was clarified to read "The actions discussed in this EA do not involve major ground 

disturbance or construction or alteration of vegetation."
APPENDIX D

Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 107

c. Chapter 1, page 5: The reader is [led] to believe that all cattle deaths are related to wolf 

kills. All predators (such as: grizzly bear; cougar; coyotes; and humans), can kill cattle along 

with natural deaths or accidents. Only facts should be identified. 

Chapter 1 page 5 was reviewed and there is no reference or implication that ALL, or even most, cattle 

deaths are related to wolves. Section 1.2 in the EA discusses the direct, indirect, and probable effects 

that wolves have on livestock production. As discussed in the EA, confirmed livestock kills do not 

represent total probable direct mortality, nor do they account for indirect damages to livestock and 

associated costs to producers. While total statewide numbers of confirmed livestock losses from 

wolves may be less than other sources of mortality, wolf depredation can create substantial hardships 

on affected individual producers.

21) One commenter questioned the value of the WS Decision Model.

The WS decision model (Slate et al. 1992) is a proven strategy for determining appropriate action 

methods. The model is not tiered in any way; rather it is expressly identified so the reader can 

understand the thought process WS uses in determining action strategies.

22) On commenter suggested birth control and holding entire packs in captivity be used as means to reduce 

lethal removal.

Section 2.5 of the EA, Alternatives Considered but Rejected from Detailed Analysis, with Rationale, 

discussed the use of birth control strategies. Sterilizing wolves could reduce recruitment and is 

counterproductive to expanding and increasing wolf populations in WA. WDFW is responsible for 

manage federally delisted wolves in WA and determines the fate of wolves. WS has no authority to 

require WDFW to issue permits to trap entire packs and then hold those packs in captivity. 

23) One commenter requested that we “please describe Wildlife Services (WS) successes and failures as they 

relate to Gray Wolf damage in MT, ID and WY. Please include reasons for the successes and the 

failures”.

Wolf damage management occurring in MT, ID, and WY deal with wolf and livestock populations and 

situations that are very different from WA. Each of those states has more livestock and more wolves, 

and has more annual wolf depredations than is expected in Washington. The use of lethal removal in 

those states occurred while the population of wolves continued to increase, proving that wolf recovery 

can occur in spite of lethal removal.

24) The final comments pertained to issues out of the scope of this EA:

a. I am a small farmer, striving for sustainability in Stevens County. I doubt I will ever 

experience serious problems with wolves, despite the fact that I raise poultry and other 

livestock. If any issues do occur, I can guarantee that they will be insignificant compared to 

the problems I face from two-legged wolves who have been dedicated to driving small 

farmers off the land for several generations now.

b. What is the relationship between the National Rifle Association and Wildlife Services?

c. Also, stop sterilizing the Yellowstone bison with your questionable GonaCon!! You have no 

business [mess]ing with the natural world.

d. If you just have to shoot wild animals, how about deer and other ruminants? They are 

MUCH more destructive to crops and gardens. Better let the wolves kill the sick wild 

ruminants and do everyone a favor (except the NRA).

e. You placed them there originally and now want to kill them, I think your dept needs better 

advisers!

f. Penalize people for killing wolves

g. Our political system has a misguided war on wildlife. I pray for the coexistence for wolves.

h. Grazing permits need to be re-examined. Public lands should not be passed down through 

some sort of "succession" from generation to generation.

i. Protect wolves, stop urban sprawl
APPENDIX D

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