### 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 , 2014Environmental 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 Availabl e 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 Metho dology

................................ ................................ ................................ ................................ ... 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

- Al ternative 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

................................ ................................ ................................ ............... 57Environmental 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

................................ ...................... 91Environmental 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 In formation System

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NRM DPS Northern Rocky Mountain Distinct Population Segment

RAG Radio Activated Guard

RCW Revised Code of Washington

T&E Th reatened 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 ass ist the Washington Depart ment of Fish and Wildlife ( WDFW ) , the United States Fish and Wildlife Service (USFWS), a nd Native American tribal governments with management of gray wol f ( Canis lu pus ) conflicts throughout the s tate

. The n eed 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

- tr apping, 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 th e 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 Plan t 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

, w hich 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 deliste d 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; Apr il 2, 2009). This boundary

falls within WDFW’s east ern 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

t hroughout the state (Washington Administrative Code 232

- 12

- 297 ). Ba s ed on the expected re

estab li shment 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 speci es 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 r eceive additional protections under the federal ESA where they are currently federally classified as endangered (74 FR 15123; April 2, 2009). Wh ere gray wolves are federally listed (those portions of Was hington west of the NRMDPS line)

, t he 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 welcome d publ ic comment for 90 days from the date of publication. If federal delisting occur s , 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 w olf depredation on livestock and public safety throughout Washington . The first likely wolf depredation on livestock was reported in Stevens County in September 2007. M ore recent wolf

attack s on livestock w ere confirmed July through September 2012

, in nort h eastern WA

. Between August and September 2012, WDFW killed seven wolves from the Wedge Pack, including the alpha male and female, i n 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 toler ance 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) p roposes to assist WDFW , USFWS, and tribes with resolving gray wolf damage, as requested by WDFW unde r WAC 232

- 1 2

- 297 and the WCMPW or similar guidance

. Act ions would include assist ing WDFW to reduce wolf conflicts to protect livestock, includ ing herding and guarding dogs, and human safety, as defined in WCMPW ( Wiles et al. 201 1 )

. WS

also proposes to assist WDFW with identifyi ng wo lf depredation event s on livestock

, provid ing a variety of non

- lethal damage management assistance to livestock producers , research (e.g., live

capture, monitoring), and public education

. At the request and direction of WDFW

, WS may lethally remove de

- listed wolves from packs ident ified as being involved in repeated livesto ck 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 guidelines 1 and Code of Federal Regulations (CFR) 2 . O n tribal lands

, WS may assist tribal governments with all forms of wolf management

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

Alternatives

A “ N o A ction ” alternative was evaluated for comparison to describe the environment al baseline. “No Action” refers to maintaining the current WS Wolf Assistance Program, which provides

technical assistan ce and non

- lethal direct control. If WS continued with the existing program (“No A ction ”)

, 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 edu c ation and outreach of wolf issues. The Proposed

A ction Alternative , Expand the Current Wolf Ass istance 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 conservatio n 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 offi cial 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 examine d

the effects on n on

- target animals

, human safety, and on social and aesthetic perspectives including public acceptance, human e ness
, and aesthetic enjoyment of wolves . The effectiveness

of the alternatives in me eting the purpose and need and how well the alternatives alleviate livestock damages is also discussed

. Th is 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 i ndicated that if Wildlife Services does not adopt the Proposed Action A lternative, 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

allow ed 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 a lternative (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 A lternatives. Some members of the public might prefer the No Action

altern a tive because WS would not kill any wolves , b ut WDFW, or its agents, would still remove problem wolves as allowed under the WCMPW ( Wiles et al. 20 11 ) 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)

.

T he Eliminate the Current Program alternativ e 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 r emovals 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 p roactive 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 an y 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 detrac t from wolf conservation and recovery (Appendix A)

.CHAPTER 1. PURPOSE AND NEE D 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 o f 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 wolv es 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

2 32

- 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 wol f management in Washington where

e mphasis 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: c attle, 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 wolve s 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

- livestoc k 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 pack s in the Eastern Washington management zone and t wo packs bordering

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

wolves (e.g., not associated with known packs) are confirmed to oc cur in northeastern Washington.CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 2 WDFW r equested that APHIS, Wildlife Services (WS ) assist with managing gray wolf damage to livestock and potential risks to human safety, as defined in WCMPW

. A s 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 case s is because WS has special expertise in evaluating and confirming livestock depredation , technical expertise in non

- lethal methods to minimize

wol f 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 manag ement 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 boundary 3 (NRMDPS) ( Figure 1). Gray wolves throughout Washington are protected under

state law as endangered ( WAC 232

- 1 2

- 297 ) , with three management zones having been

establis hed 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 requ ests

3 The NRMDPS in Washingt on includes that portion of Washington east of Highway 97 from the British Columbia border south to Monse, H ighway 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 197 3 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 Y NP

. Wolves were protected

as a “non

- essential experimental population” unde r the federal ESA within a specified zone that included portions of Idaho, Wyoming

, and Montana

.

W hen t he WCMPW was initiated in 200 7 , gra y 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.

S ubsequently, 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, includ ing the portion of th at 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 t he only protections in effect in this area are those established by sta te 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 E SA 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 th e 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)]

. W S determined it would only

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

WDFW ’s conservation and managem ent objectives and goal s as defined in detail in the

WCMPW or similar guidance

.

1.2 N eed for Action

Direct predation on livestock

The WCMPW calls for recovery of wolves in Washington , which provides a reason able 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 recov ery ( 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 li vestock 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 numbe r, 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 toler ance for overall wolf recovery ( Wi les 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 lo sses

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 asCHAPTER 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 Enforcem e nt of Rule Pending Judicial Review Conditioned on Providing Security

, one Oregon ca ttle producer declared t hat 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 a l. , No. 149672 (Or. Ct. App. Nov. 15, 2011) order staying enforcement of rule pending judicial review )

. For the confirmed wolf kills, h e received a compensation payment in the amount of $800 4 but 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 ca se 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 require s 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 pred ation 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 o f 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 nee ds 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, O DFW 2010 ). Data from the NRMDPS suggest
that individual wolves do not aut omatically 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 W S for

I daho (USDA 2011 a ). The authors measured the likelihood for depredation to occur from wolves, black bears, cougar s
, and coyotes and showed that individual wolves were more likely to depredate on sheep and cattle than individual coyotes, bears

, and cougar s.

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 ( O DFW 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 vulnerabl e 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 becaus e 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 iceb erg” 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, improv ed 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

Wil dlands, 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 i ndirect) losses. In a nother 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

lo sses 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 opera tions.

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

cost s 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 weightCHAPTER 1. PURPOSE AND NEED FOR ACTION

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

har assment 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 unstre ssed, 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 chas e 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, cal ve 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 ( O DFW 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, g uard dogs appear to be

more effectiv e 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 wo lf depredation. Working dogs and trained herders may be more effective for protec ting sheep flocks than cattle ( O DFW 2010 )

.

In Washington , some wolves are likely to occupy areas near human habitation or areas used for recreation which could put pets or w orking 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.). A s 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 NR M DPS which

is defined as the area east of H ighway 97 from the British Columbia border south to Monse, Highway 17 from Monse south to Mesa, and Highway 395 from Mesa south to the OregonCHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 8 border

. Nonlethal w olf 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 sov ereign tribal

gove rnments 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 confli cts in other states or by other predators

in Washington

. Even when wolf numbers increase, lethal removals would be limited t o th ose constraints presented by WCMPW , USFWS regulations, or tribal autho rity

.

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

incident

, and is likely t o occur on private

, state, tribal

, or federal land including U SFS 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 locatio ns or times where such damage will occur cannot be predicted due to the mobil ity and unpredictability

of wolves, and the distribution of livestock across the Washington landscape. Ther e fore, t his EA anticipates all substantive environmental issues that are likely to exist where wolf dam a ge management may occur . The WS Decision Model (Slate et al. 1992) is the s ite

- specific mechanism for determining the most appropriate actions to take within the scope of actions allowed under any NEPA decision. Any sub stantive 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

.

A ctions 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 be en 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 fo r depredation. Other than on sovereign tribal lands, only WDFW or USFWS will make the final confirmation of repeated livestock depredation. L ethal take of federally delisted wolves under WDFW control is allowed by livestock owners, (including family membe rs and authorized employees) on private land they own or lease at all listed statuses, with an issued permit, after documented depredation (injury orCHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 9 killin g) 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 appl ies 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 carc ass 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 dep artment 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 produ cers or permittees. The specific non

lethal 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 fe derally 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 wou ld be conducted only at the request of WDFW

, USFWS, affected property owners (for nonlethal assistance)

, and tribal governments. WS h as 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

request s to remove problem wolv es. 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 P roposed A ction Alternative , on tribal lands WS would conform to similar implementation guidelines for the management of wolf depredation including limitations on theCHAPTER 1. PURPOSE AND NEED FOR ACTION

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 ).

R equests for assistance by s overeign tribal governme nt s in the foreseeable future are p ossible 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

. A ny 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 pop ulations : 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 pe rsisting 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 Washin gton 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

.CHAPTER 1. PURPOSE AND NEED FOR ACTION

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 W S , in consultation with WDFW , USFWS, and affected sovereign trib al government s , determines that the need for action, issues driving this EA, environmental conditions, or wolf management plans have change d 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 i n Section

1.2

, woul d be expected to increase over time as Washington ’s wolf populations grow and expand

. The WCMPW use s a daptive management to incorporate new information into

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

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

as conducted by WDFW is e xpected to continue into the for e seeable future and result in an eventual state delisting

.

1.6 Decision to be Made

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

WS is the lead a gency 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 ( W DA), 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 g overnments ?

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

 What are the likely environmental effects o f the alternatives, and could the proposed action have significant effects on the quality of the human environment and therefore

req uire an EIS?

1.7 Summary of Public Involvement Efforts

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

with W S 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 2011 a , 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 b y posting the notice of its availability on the W S

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

, b y issuing a legal notice in

the Olympian on December 17, 2013 , and by posting t he pre

- decision al EA onCHAPTER 1. PURPOSE AND NEED FOR ACTION

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 instruction s 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 summa ry of the public comments and responses i s 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 Rela tionship of this E A to other Environmental Documents

Final Rule to Delist NRMDPS

On 5 May 2011, USFWS published a final rule to remove protections of the E SA 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. B ackground information on the NRM gray wolf population was contained in the

USFWS 2 April 2009, F inal R ule (74 FR 15123) http://www.regulations.gov 5

201 1 Wolf Conservation and Management Plan for Washington.

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

the WCMPW to th is 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 P roposed

A ction Alternative

. Th e 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 se rved 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 ou r 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 require d 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.CHAPTER 1. PURPOSE AND NEED FOR ACTION

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 c entral Idaho. Part of the analysis in the EIS as sessed 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

W S cooperates with land and wildlife management agencies to resolve wildlife damage pro blems in compliance with applicable federal

, s tate and local laws.

1.9.1 Authority of Federal and State Agencies in Wolf Damage Management

APHIS

- Wildlife Services

The W S 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 dynami c 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 confli ct 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 resourc es under its jurisdiction, as integrated with its multiple use responsibilities. Similar to the USFS, BLM and W S 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 l easee.

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,

a nd 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 partn erships, employing scientific excellence, and developing a workforce of conservation leaders.CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 14 U nited 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 r esident wildlife. The USFS r ecognize s 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 W S in the development and

annual review of wildlife damage management plans governing W S ’ activities on National Forest System lands and to cooperate in W S ’ 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 WD M work plans. In this way, the USFS ensure s 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

“t he commission, director, and the department [WDFW] shall preserve, protect, perpetuate, and manage the wildlife and food fish, game fish, and shellfish in state wat ers 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 L aws , Policies and Executive Orders

Several f ederal and s tate laws regulate wildlife damage management. W S complies with

relevant federal and s tate laws, and consult s and cooperate s with other agencies as appropriate.

Bureau of Land Management

Under the Act of 193 1 , as amended, (7 U.S.C. 426

- 426c), BLM and W S , along with the states, cooperate to manage animal damage on B LM lands. Similar to the USFS, BLM and W S have entered into a MOU which identifies the roles and responsibilities of each agency in animal damage management operations and coordination, and NE PA 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 W S in the development and annual review of animal damage management work plans governing W S ’ activities on BLM lands and to cooperate in

W S NEPA processes.CHAPTER 1. PURPOSE AND NEED FOR ACTION

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 15 Executive Order (EO) 12898

- Federal Actions to Address Environmental Justice in Minority Populatio ns 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 treatmen t 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

progra ms. 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 ar e 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 Saf ety 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 P roposed A ction

Alternative would not increase environme ntal 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 furthera nce of the purp oses 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 a ny endangered or threatened species. W S

conducts Section 7 Consultations with the US FWS 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 state s

. WDFW or its agent is authorized toCHAPTER 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 airc raft, boats, or other vehicles).

N ational E nvironmental P olicy A ct

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

Pre sident’s Council on Environmental Quality (C EQ ) Regulations, ( 40 CFR Section 1500

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

.

O ne purpose of any EA is to “. . . briefly provide sufficient evidence and analysis for determining w hether 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 E IS 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) con sult 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 a nd 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

n ot 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 or ders, 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 2/3 rd of WA; however, the USFWS can, throughCHAPTER 1. PURPOSE AND NEED FOR ACTION

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 s cope 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 "remo ve 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 W S , 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 W S (Appendix B) , W S is designated as the lead agency concerning animal damage management activities involvin g 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 activitie s 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 W S in the development and annual review of wildlife damage management plans gove rning W S ’ activities on National Forest System lands and to cooperate in W S ’ 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 Regi onal Forester and under annual WDM work plans.

Washington Endangered Species Act

The Washington E SA ( 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 an d 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 stat e without cooperative management or removal of

threats

.

WDFW

- Mandate ( RCW 77.04.012 )

RCW 77.04.012 mandates that “t he 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, w olf damage management will be implemented by WDFW according to the WCMP W ( Appendix A ). WS developed three reasonable alternatives in response to the request assist with wolf damage management in WA

. The Current Program “ N o A ction” alternative was evaluated for comparison to describe the environment al 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 wolv es ( Appendix A ). T he second alternative

is the Elimina te 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 A lterna tive, 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 , USF WS, 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 serve s 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 an d 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, fl adry, 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 provide s the results of confirmed, probable, and possible wolf conflict investigations to

WDFW /USFWS , but would not provide lethal rem ov al 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 u nder which gray wolves are managed by

WDFW

.

The WCMPW describe s measures the WDFW w ould take to conserve and manage wolves,

i nclud ing actions that coul d be taken to protect livestock from wolf depredation

. The following

summarizes the primary components of the WCMPW, but removes WS from conduct ing lethal removal or trapping of wolves for WDFW /USFWS under th is “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 allow s 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 grazi ng 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 o ff 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 non

lethal 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 inj urious 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 case

specific basis, but would especially be considered during endangered and threatened status.

WS would not capture o r relocate wolves under this alternative

.

o Any relocation would be conducted by WDFW, or its agents, in co nsultation with the appropriate land management agency and the USFWS , if wolves are federally listed in that portion of the state.

o Lethal control to re solve repeated livestock depredations: WS would not conduct lethal removal under this alternative; however, l ethal 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, an y 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 feder ally listed. During state endangered and threatened status, lethal control would be conducted by WDFW or its agents. If aCHAPTER 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 reso urces 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 priva te 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 pr ovision 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 flexibilit y 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 manage ment 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, cert ain 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

- th reatening 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 an d 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 nee d 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 soci al 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. Thi s 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 repe ated 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 produc ers, 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 compe nsated 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 los ses 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 an d aid wolf recovery.

The role of WS under this alternative would be indirect : WS c ould provide advice to producers

on the use of non

- lethal methods

, c ould 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 non

lethal preventive methods such as c ultural 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 th ese 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

livest ock 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 regu lar basis to detect any disease, natural mortality, or predation, 6) keeping livestock away from areas of historic wolfCHAPTER 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 o r 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 area s, 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 prov ided 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 e t 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 the y 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 w ith 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 effect iveness 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 (S hivik 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 frighteni ng 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 c ould 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 eut hanized 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 foo thold traps be checked every 24 hour s.

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 ca pture of non

- target species smaller than wolves ( e.g ., red fox, coyote), they cannot preclude the occasional capture of larger non

target species such as cougars or black bears. They do, however allow for the option of releasing

non

- target animals which m ay 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 ar ound the lower leg with a spring

powered 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

con tribute to the selectivity of this device. As with foot

- hold traps, when foot snares are used asCHAPTER 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 c ougar s 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 immo bilized , 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 Sn ares 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 . I mproved methods for use are being developed for live

- trapping wolves and other carnivores (Olson and Tisch aefer 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 radio

transmitting 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

us ing 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

ei ther 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 w henever the predator

attempts t o prey on the protected resource, so it is less likely to identify conditions when it canCHAPTER 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 efficie ntly used when there

are radio

- collared wolves involved and the landowner/resource manager assists with the implementation. WDFW authorizes t he 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.pd f ).

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 si tuation, and the level and likelihood of continued depredations. There w ould 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 Medi cal Association ( AVMA 20 1 3

, Julien et al. 2010) would be available to WDFW or its agents , USFWS, and tribes . Additional

lethal methods used under Alternative 1 would incl ude 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 ani mals 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 t han 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).

A erial 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 shooti ng 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 tempe ratures 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 i s the speed of action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the animal (AVMA 20 1 3 ). 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 provide s 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

U nder 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 describe s measures WDFW w ould take to conserve and manage wolves,

i nclud ing actions that coul d be taken to protect livestock from wolf depredation . Alternative 2 encompasses all the primary c omponents of the WCMPW and all actions and components listed in Alternative 1, b ut removes WS as a n assisting agency to WDFW , USFWS, and tribes . While

the WCMPW references WDFW using WS for assisting with wolf recovery, WS would not

ac tually participate i n 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 mitigati on measures against the accidental impact to target and non

- target wildlife, public safety, or personnel safety during wolf control activities conducted by others.CHAPTER 2. DESCRIPTION OF ALTERNATIVES

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 W S 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 livestoc k depredation and after unsuccessful attempts using non

- lethal meth ods had been documented. The P roposed A ction

Alternative encompasses all of the methods discussed in Alternative 1 with WS conducting the

direct activities

.

The role o f 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 W S policy, it would only provide direct w olf damage management on properties after Agreement for Control or other work authorization documents have been completed. On federal public lands, p lanned activities must b e 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 o nly 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 manage d 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 mana gement 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 in crease ( 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 confirm ed repeated depredating wolves, WS would use its Decision M odel (Figure3) (S late 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

rest rictions 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 cons iderations).

W hen responding to requests from WDFW or tribes, l ethal removal of wolves from packs causing repeated livestock depredation would only be done after unsuccessful attempts to use

non

- lethal methods ha d been documented. While the WCMPW dictate s this for WDFW, WS would only agree to lethal removal on tribal lands under similar guidance

.

2.3.2 Description of Lethal Method s 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. TheCHAPTER 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 t ribal final decision

. The lethal wol f 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 20 1 3 , Julien et al. 2010). Additional lethal methods used under Alternative

3 (the Proposed Action Alternative) would incl ude 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 conjun ction 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 probl em. 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 di stance. 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 s ingle

- 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) cit ed 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 . I mproved 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 (Beuthana sia®

- 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

unco nsciousness progressing to death. The primary advantage of barbiturates is the speed ofCHAPTER 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

W S 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 non

target wildlife. While the WCMPW may be updated and permit condition s can change,

c urrently, 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 tr aps and snares are placed at major access points when they are set

.

 W S personnel are trained in identification of wolves and wolf sign.

 W S will maintain regular contact with appropriate state and federal agencies, report ing 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.

 W S will maintain re gular 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 W S personnel determine that they will not survive.

 AVMA (20 1 3 ) rec ommended 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  W S records and monitors all WS wolf removal through its Managemen t 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 v ehicle 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.

 Th e WS program is conducted under Cooperative Agreements and MOUs with federal and state agencies. National MOU’s wit h 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, f oot

- 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 decis ions. Where non

target 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, non

target 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 betwe en 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, grizzl y 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 revie wed 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 i nformation 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 pr e

- 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 thos e 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 be ar, 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 Li sted 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 a nd 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 non

trapping alternatives to achieve their objectives if captu re 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 toCHAPTER 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 sufficie nt 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 pr edator 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 t o 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 tr eatment 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 replac e 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 activi ties, 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 integrit y.

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 t o 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 t heir objectives unless otherwise approved on a case

- by

case 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 northwe stern 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 t he 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 tr aps. 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 cas e

- 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 distinguishi ng 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 kn owledge 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

trap ping, 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 federall y 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, animal

husbandry operations include, for example, barnyards, corrals, poultry operations, animal enclosures, and simil ar 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 us ing 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

ancho r such as a tree or, if such anchorage is not possible, to drags of at least 500 pounds dead weight or Livestock Protection Company ® heavy

duty drag.

 If foot snares are used for the capture of black bears, wolves, or cougars, all snares used will be grizz ly 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 bearCHAPTER 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 prog ram 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 a vailable to the public.

2.4 Summary of Actions allowed by Alternative

Table 1 . Summary of W S activities that would be applied under each alternative ( A dapted 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 r emoval 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 W olf D amage Ma nagement without a T hreshold of L oss R equirement

This alternative would differ from the P roposed A ction Alternative in that it would have

removed th e 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 l oss. 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 st rategies 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 goa ls.

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 s trategy 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 th e 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 wo lf 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 alterna tive would direct all WS program efforts toward planned, tota l elimination of wolves.

This a lternative was not considered in detail because e radication 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 red uce damage, not to engage in large

- scale eradication or suppre ssion, and e radication of wolves is not acceptable to most members of the public.

Agencies Exhaust All Non

- lethal Methods Before Attempting Lethal Methods

Under this a lternative, 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 impra ctical ( 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 appe ars to haveCHAPTER 2. DESCRIPTION OF ALTERNATIVES

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 39 habituated). This a lternative 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 eff ective, 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 shor t

term 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. T his issue is outside the scope of any decision that WS

would make as a result of this EA.

Live C apture and R elocation of Depredating W olves

.

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 p roblems. 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.CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

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

T he 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 alternative s 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 Washingto n 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 e ffects 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 weighe d 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 preparatio n 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 s ignificant 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.

P up survival is primarily dependent on size of pack and age of pup because multiple packCHAPTER 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 res ponsible 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 n ot 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 wol f

c onservation and management as discussed in the WCMPW ( Wiles et al

. 201 1 )

. Based on a review of available literature in USDA (2011 a )

, 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 a re 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 o f 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 pro ducers’ 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 includ e harassment of livestock by wolves

, fence repairs after wolves chase livestock through fences

, costs to gather and re group 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. T hese and other

indirect effects that wolves have on livestock are discussed unde r Section 1.2

.

Tribal Lands

Tribal wildlife managers with responsibilities to protect and manage treaty

- reserved wildlife

resources in Washington may meet wolf management nee ds 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 t ribes in Washington to solicit tribal concern s for this

EA. No issues were provided from these tribes. Because extensive outreach occurred during theCHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 42 preparation of the WCMPW , no new issues ar ose from the outreach and consultation associated

with this EA.

As discussed under the P roposed A ction Alternat ive , WS determined that WS work on tribal lands would conform to similar depredation management protocol s 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 ef fects 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 W ildernes s Stud y 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 f

ish and wildlife with the State s 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 WD FW in

accordance with the WCMPW and coordination with the Regional Forester

.

In accordance with Forest Service Manual 2323.33 c , the Regional Forester may approve predator damage ma na gement 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 Wi lderness 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 con flict do not ex ist. 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, 200 4 memorandum (No. 2004

- 140) from BLM

Director to all Washington and Field Office Officials )

. WS f ollows BLM's Interim Management Policy for Lands Under Wilderne ss Review, H

- 8550

- 1 (1 995 )

, and the MOU between BLM and

WS.CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

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 200 4 ). 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

a reas of conflict do not exist. If WS did not remove the wolf, as requested by WDFW or their

agents c ould remove the wolf. Therefore, WS a ctions would have no effect on wilderness characteristics such as size, naturalness, solitude, aesthetics, primitive o r 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 L ands un der 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 an d this outside the sc ope 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 authorizin g 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.CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 44 Other resources

The actions discusse d 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/quanti ty, 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 w ill 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

– T emporary, seasonal impact, year round or ongoing (intensity);

Likelihood of the Impact

– (intensity);

Geographic Extent

– L imited to the local unit area or to the management zone (context); and

Legal Status

- O f the species that may be affected ; and conformance with regulations and policies that protect the resource in question (context).

The analys e s 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

re sponsibility 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 WD FW

, 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

valu es 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 a ction 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 pr otect 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 Impa ct 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 solita ry 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

popu lation 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 WashingtonCHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 46 wolves continue to reproduce and as wolves from other states and Canada ente r 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 mor tality, unintended mortalities

, or westward dispersal.

T he 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 . T here are documen ted 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 individual s

. 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 whi le 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)

. Are as 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 un der 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 rem oval. 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 i ts efforts away from proactive nonlethal measures. Ultimately, this alternative could hamper WDFW wo lf recovery and conservation efforts (Appendix A).CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

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

W S 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 m ethods available to WS are also available to WDFW

.

WS’s use of traps and foot snares in Washington ha s not presented any safety risks to people (MIS 2012). T his 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

ma ny 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 abili ty 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 c ould 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 produ cers, 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 ma nagement 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 a nd 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)

.CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

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, l ivestock 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 incl ude 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 anima ls) (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 benefit ing 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 peo ple 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 becaus e 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 th at, 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 w ould still remove problem wolves ( Appendix A ) , as could tribal author ities. T he 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 andCHAPTER 4. ENVIRONMENTAL CONSEQUENCES

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 l ikely 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 te mporarily 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, s caring wolves away from one specific location in an area with large

numbe rs 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 predatio n 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 sugge sted 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 ceas ed 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 re

colonization (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 non

breeders 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

- collaredCHAPTER 4. ENVIRONMENTAL CONSEQUENCES

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 centr al 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 wol ves 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 nea r 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 re cent 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).

Bang s 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 w olves 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 man y 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 b een 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 reduci ng 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 method s, 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 thanCHAPTER 4. ENVIRONMENTAL CONSEQUENCES

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 wol f 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 t hree 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 t he 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 pred ation 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 succe ssful 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 depredati on. WDFW has indicated that it would target wolves for lethal control, similar to the P roposed A ction Alternative

, however without additional assistance from WS, service to landowners may be reduced or delayed and WDFW would have to redirect their personne l 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

U nder 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 lan downers 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 c ould t ake the same actions as those described under the No Action alter n ative , 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 environme ntal 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 trib al governments have authority o n 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 a ttacked livestock are instructed to immediately

call WDFW

, USFWS, or county official s

. 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 wher e a need exists and in accord with the requirements for removal . In additio n, producers in areas where wolves are managed by the state (currently within the NRMDPS boundary), and who have been issu ed a WDFW permit or c atch 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 Impa cts on non

- target animals and human safety

Non

- target animals

W S would have no effect on non

- target species or humans under th is alternative.

Human Safety

W S would have no effect on human safety under th is 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 u nlikely event that wolves threatened human safety, WDFW , USFWS, and tribes c ould

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 expe ri ence 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 unaccep table 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, l ivestock 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 pr efer if wolves were removed from Washington

.

Because WDFW (Appendix A) , USFWS, or tribes c ould take necessary action to lethally remove wolves under this alternative, ultimately, social perspectives would be expected to be similar to

the No Action Alter native.

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 enjo yment

Under t his 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 c ould 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 A lternative is to assist livestock producers , tribes, WDFW, and USFWS with an integrated approach of technical assistan c e, 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 co ntinue 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. ThisCHAPTER 4. ENVIRONMENTAL CONSEQUENCES

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 54 alternative is almost identical to the No Acti on 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 guidelin es. 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 redu cing wolf damage while benefit ing wolf conservation and recovery in WA.

4.3.1 Impa ct 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

conditi ons of the WCMPW or similar guidance and assist USFWS with wolf conservation efforts under ESA guidelines

. This alternative would allow WDFW, USFWS, a nd 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 o n the gray wolf population in Washington would be similar or lower than

A lternative s One and Two. WDFW is already implementing the WCMPW and w oul d continue to respond to wolf damage complaints in the absence of WS assistance ( Appendix A ). Without

WS assi stance, 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 WDF W or tribes with lethal and non

lethal wolf damage management and USFWS with non

- lethal management and lethal management under provisions of the ESA . By providing W DFW and tribes with l ethal 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 NoCHAPTER 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 P roposed

A ction A lternative 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 t ribal 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

T here would be little to no difference in the effect to non

- target animals because WDFW, its

agen ts, USFWS, WS, and tribes could use the same tools. N eck snares have potential to a ffect

non

- targ ets. The exposure of non

- target animals to neck snares is mitigated through consulta tion

with the USFWS under Section 7 of the ESA . N eck 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 non

target animals such as bear and cougar, the level of use of lethal tools wou ld 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 r esult 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 de velopment 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 conflue ntus ), 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 ca ptured 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 ex istence 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' deter minations of affects from WS' proposed actions in WA.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 impl ementation 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 concl uded there was very little, if any, risk to the public from WS aerial shooting activities (Appendix C ). Other a nalyses of aircraft accidents by WS concluded that the accident rate for WS pilots and aircraft is not significantly different from rates report ed 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 belie ve 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.

A ppropriate 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, t here 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 genera lly occur. WS’s use of traps and snares ha s 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

fro m 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 da mage management and on the removal of wolves under the Proposed A ction Alternative would be expected to be similar to the No Action and Non

- lethal only alternative s 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 holdi ng l ethal removal permits , additional take is unlikely for the reasons discussed

under Section 4.3.1.

With regard to the humane treatment of wolves, the propos ed 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 manage ment program may be enhanced under the P roposed A ction

A lternative 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 th at 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 wol f is r emoved. 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 area s. 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

aesthe tically 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 gett ing 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 w ill prob ably 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 P roposed A ction Alternative would likely be more efficient in resolving depredation than the No Action and Eliminate the Wolf Assistance Program alternatives in alleviating additional livest ock 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 c onflicts. WS personnel may be more readily available to provideCHAPTER 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 jeop ardized. 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 dama ges. 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 conse rvation 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 P roposed A ction

Alternative . Because repeatedly depre dating 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 depre dations 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 wol f 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 P roposed A ction

Alternative because WDFW and tribes would continue to take necessary actions to remove repeatedly depredating/problem wolves if WS did not. The primary difference s between the

alternatives are the probable increased efficacy of the P roposed A ction 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 remov al of problem wolves . The decision to be made is to respond or not respond to their requests dir ecting when, where, and which wolves should be removed. T he 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

a ny 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 

### CHAPTER 5

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Mack, J. A., W. G. Brewster, and S. H. Fritts. 1992. A review of wolf depredation on livestock and implications for the Yellowstone area. (Pages 3

- 20) in J. D. Varley and W G. Brewster, editors. Wolves for Yellowstone? A report to the United S tates Congress. Volume IV Research and Analysis. National Park Service, Yellowstone National Park, Mammoth Hot Springs, Wyoming, USA.

Mech, L. D. 1995. The challenge and opportunity of recovering wolf populations. Conservation Biology 9: 270

- 278.

Mech . L. D. 2001. Management of Minnesota’s recovering wolf population. Wildlife Society

Bulletin 29: 70

- 77.

Mech. L. D. 2012. Is science in danger of sanctifying the wolf? Biological Conservation 150:

143

- 149.

Mech, L. D., and L. Boitani. 2003. Wolf social ecology. (Pages 1

– 34) in L. D. Mech and L. Boitani, editors. Wolves: behavior, ecology and conservation. University of Chicago Press, Chicago, Illinois, USA.

Mech, L. D., S. H. Fritts, and M. E. Nelson. 1996. Wolf management in the 21st cen tury: from public input to sterilization. Journal of Wildlife Research 1: 195

- 198. <http://www.npwrc.usgs.gov/resource/mammals/wolfman/index.htm (Version 02MAR2000).>

Mech, L. D., E. K. Harper, T. J. Meier, and W. J. Paul. 2000. Assessing factors that may predispose Minnesota farms to wolf depredations on cattle. Wildlife Society Bulletin 28:

630

- 635.

MIS (Management Information System). 2012. WS State Director’s Office, 720 O’Leary St NW, Olympia, WA 98502.

Muhly, T. B., and M. Musiani. 2009. Livestock depredation by wolves and the ranching economy in the Northwestern U. S. Journal of Ecological Economics 10: 1016.

Muhly, T. B., M. Alexander, M. S. Boyce, R. Creasey, M. Hebblewhite, D. Paton, J. A. Pitt, and M. Musiani. 2010. Differential risk effects of wolves on wild versus domestic prey have consequences for conservation. Oikos 119: 1243

- 1254.CHAPTER 5. LITERATURE CITED

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 64 Musiani, M., C. Mamo, L. Boitani, C. Callaghan, C. Cormack Gates, L. Mattei, E. Visalberghi, S. Breck, and G. Volpi. 2003. Wolf depredation trends and the use of fladry barriers to protect livestock in western North America. Conservation Biology 17: 1538

- 1547.

Nass, R. D., and J. Theade. 1988. Electric fences for reducing sheep losses top predators. Journal of Range Management 412: 251

- 252.

Niemeyer, C. C., E. E. Bangs, S. H. Fritts, J. A. Fontaine, M. D. Jimenez, and W. G. Brewster.

1994 . Wolf depredation management in relation to wolf recovery. Proceedings of the

Vertebrate Pest Conference 16: 57

- 60.

Oakleaf, J. K., C. Mack, and D. L. Murray. 2003. Effects of wolves on livestock calf survival

and movements in central Idaho. Journal of Wildlife Management 67: 299

- 306.

Olson, J. F., and R. Tischaefer. 2004. Cable restraints in Wisconsin: a guide to responsible use. Wisconsin Department of Natural Resources, Madison, USA and Wisconsin Trappers

Association.

Oregon Department of F ish and Wildlife (ODFW) 2010. Oregon Wolf Conservation and Management Plan, 2005 and Updated 2010. Oregon Department of Fish and Wildlife. http://www.dfw.state.or.us/Wolves/docs/Oregon_Wolf_Conservation_and_Management_Pl an_2010.pdf

Oregon Department of Fish and Wildlife (ODFW). 2012. Oregon depredation list for WS. A report provided to WS by Russ Morgan, Wolf Coordinator, ODFW, La Grande, Or egon.

Paul, W.J. and P.S. Gipson. 1994. Wolves. Pp. C123

- C129 in : S. E. Hygnstrom, R. M. Timm, and G. E. Larson (Eds.), Prevention and Control of Wildlife Damage. Coop. Extension Div., IANR, University of Nebraska, Lincoln, NE.

Schultz, R. N., K. W. Jonas, L. H. Skuldt, and A. P. Wydeven. 2005. Experimental use of dog

training shock collars to deter depredation by gray wolves. Wildlife Society Bulletin 33:

142

- 148.

Shelton, M. 2004. Predation and Livestock Production

– Perspective and Overview. Sheep and

Goat Research Journal Volume 19. <http://www.sheepusa.org/index.phtml?page=site/ news_details&nav_id=4e92bbbcf5184ed243442d8fa0a7c677&nav_parent_id=601e0a31bbf

6a0ef56f1f0591aa0dc78&volume=Vol ume%2019,%202004%20

- Special%20Edition:%20Predation>

Shivik, J. A. 2004. Non

- lethal alternatives for predation management. Sheep and Goat

Research Journal 19: 64

- 71.

Shivik, J. A., and D. J. Martin. 2001. Aversive and disruptive stimulus applicatio ns for managing predation. Proceedings of the Wildlife Damage Management Conference 9: 111

- 119.CHAPTER 5. LITERATURE CITED

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 65 Shivik, J. A., A. Treves, and P. Callahan. 2003. Non

- lethal techniques for managing predation: primary and secondary repellents. Conservation Biology 17: 15 31

- 1538.

Slate, D. A., R. Owens, G. Connely, and G. Simmons. 1992. Decision making for wildlife damage management. Transactions of the North American Wildlife and Natural Resource

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- 62.

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- 231.

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- lethal deterrent programs: building tolerance for wolf restoration in the Rockies. Pages 141

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Treves, A., R. R. Jurewicz, L. Naughton

- Treves, R. A. Rose, R. C. Willging, and A. P. Wydeven. 2002. Wolf depredation on domestic animals in Wisconsin 1976

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- 241.

Urbigkit, C. and J. Urbigkit. 2010. A review: The use of livestock protection dogs in association with large carnivores in the Rocky Mo untains. Sheep and Goat Research Journal 25: 1

- 8.

USDA, 2006. Final Environmental Assessment for the Management of Wolf Conflicts and Depredating Wolves in Michigan. United States Department of Agriculture, Animal and Plant Health Inspection Service, W ildlife Services, Okemos, Michigan, USA.

USDA, 2008. Final Environmental Assessment for the Management of Wolf Conflicts and Depredating Wolves in Wisconsin. United States Department of Agriculture, Animal and Plant Health Inspection Service, Wildlife Se rvices, Sun Prairie, Wisconsin, USA.

USDA. 2010. Idaho Wildlife Services wolf activity report fiscal year 2009. United States Department of Agriculture, Animal and Plant Health Inspection Service, Wildlife Services, Boise, Idaho, USA.

USDA. 2011a. En vironmental Assessment, Gray Wolf Damage Management in Idaho for Protection of Livestock and other Domestic Animals, Wild Ungulates, and Human Safety.

USDA APHIS

- WS, Boise, Idaho.

USDA. 2011b. Final Environmental Assessment, Predator Damage Management in Nevada. USDA APHIS WS, Reno, Nevada.

USFWS. 1994. The reintroduction of gray wolves to Yellowstone National Park and central Idaho: Final environmental impact statement. U.S. Fish and Wildlife Service, Denver, Colorado, USA.CHAPTER 5. LITERATURE CITED

Environmental Assessment

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.

USFWS. 2008. Environmental Assessment and Finding of No Significant Impact for Proposed Revision Of Special Regulation for the Reintroduction of Gray Wolves Into the Central Idaho and Yellowstone Areas. U.S. Fish and Wildlife Service, W ashington D.C., USA.

< http://www.fws.gov/mountain

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- 15, 2009. U.S. Fish and Wildlife Service, Washington D.C., USA. <http://www.fws.gov/ mountain

prairie/species/mammals/wolf/wyomingStatus09/05152009.html>

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and Wild life Service, Ecological Services, Helena, Montana, USA. http://www.fws.gov/mountain

prairie/species/mammals/wolf/annualrpt0 9/FINAL_AR_FWS_2009_Recovery_Program_U pdate.pdf

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– State and Mexico Gray Wolf Listing ( Canis lupus ), as Revised. 5

- Year Review: Summary and Evaluation. U. S. Fish and Wildlife Service, Washington Office, Arlington Virginia.

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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.

.APPENDIX A

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 67 Appendix A : WDFW Letter



## RECEI V ED

JAN 14

· 2013

- =

S t ate of W a s h i n g t o n 

### Department of Fish and Wildlife BY:

Mailing Addres s : 600 Capitol Way N

, Olympi a

, WA 985 0 1

- 1 0 9 1

, (360) 90 2

- 220 0

, TDD ( 3 60) 90 2

- 2207

Main Office L ocatio n : N a t u ra l Resour c es Building

, 1 111 Wash i n g t on S t r eet S E

, Olympi a

, WA

January 11, 2013

R og e r W o o druff

S t a t e D i r e c t or Wildli f e Services for Washington and Alaska

U S D A A ni m a l a nd P l a nt H e a lth I n s p e c t i o n Ser v i ce
7 2 0 O ' L eary S t r

e et N ort h we s t

Ol y mp i a, W a s hi n g

ton 9 8 50 2

D e a r Mr. W o o druf

f :

T h a nk y o u for y o ur recent l e t t er a nd f o l l ow up q u e s t i o n s requ e s ti n g in f o r m a t i o n a nd c l a rifi c a tion

r eg a rding t h e W a s hin g ton D e p a rt m e nt of F i s h a nd Wildl i fe's ( WDF W ) imp l e m e n t a tion of

W a s hi n g to n 's W o lf C o n s e r v a tion a nd M a n ag e m e nt P l a n ( P l a n )

. The P l a n w a s a d o p t e d b y t h e
W a s hin g t o n F i s h a nd Wildli f

e C o mm i s s i o n in D ec e m b e r 2 011 a nd impl e m e nt a t i o n b eg a n immediately

. WDFW has b e e n s o m e w h a t s urpri s e d b y h o w q uickl y W a s hi n g t o n ' s w o l f p o pulat i o n
h as i n c r eas e d a nd t h e l ev e l of c o nfl i c t s e x p e r i e n c e d ov e r t h e p as t several m o nt h s.

W e a r e r e q u e s tin g t h e as s i s t a n ce of Wildli f e S e r v i ce s ( W S) in h e

lpi n g u s a dd r

ess w o l f c o nfl i c t s a nd

in ca ptur e a nd m o nit o ri n g eff o r t s f o r m a n ag e m e nt and rese a r c h as p a rt of impl e m e nti n g t h e P l a n

. We r e q u est WS's p a rt i ci p a t i o n i n t h ese a c ti v it i es any w h ere in t h e s t a t e w h e r e WDFW i s t h e l ea d

. W e a l so as k t h a t W S as s i s t u s w e r e t h e U.S. F i s h a nd Wildli f e Ser v i ce h as m a n ag e m e nt a u t h o ri t y
th r o u g h t h e E n d a n g e r

e d S p e c i es A c t

, but h as a uthor i z ed WDFW t o ta k e m a n a g e m e nt a c t i o n s

.

WDFW h a s b e e n t r a ppi n g
, ca pturin g
, a nd m o ni t o rin g wo l v e s s i n ce 2 0 0 8

, a nd w e c ur r e ntl y h a v e

e i g h t c o nfir m e d pac k s and four s u s p ecte d pac k s b e i n g moni t o r e d b y t h e D e p a rt m e nt a nd / o r

co o pe r a ti n g tr i b es

. W o l ves were kill e d b y W D F W thi s ye a r f o r t h e fi r st tim e in r

e s p o n se t o

c h r o ni c d e pre d a t i o n o f li vesto c k

. Our eff

o r t s t o kill w o l ves inclu d e d tr a ppi n g a nd s h o o ti n g
, b o th

f r o m t h e g round a nd w ith t h e a id o f a h e li c o p t e r. T h ese l e t h a l re m ova l e f f o r t s w ill c o ntin u e b y

W D FW r eg a rd l ess o f w het h er WS i s a b l e to as s i s t u s. W D FW i s a ut h o r i z e d a nd p l a n s t o imp l e m e nt

a v a r i e t y o f w o l f

- li v e s t o c k m a n ag e m e nt m ea s u r es i n c l udi n g: p r

ev e nt a t i ve a d v i ce, d e t e rr e n t s
, h a r as s m e n t

, a nd l e t h a l r e m ov a l in cases of c h r

o n i c d e p r e d a t i o n

. L e t h a l r

e m ov a l aut h o ri ty f

o r WDFW inclu d es u s i n g foo t h o l d tr a p s, s h oo t in g ( includi n g a e r i a l te c hniq u es), a nd s n a r es.APPENDIX A

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 68 R oger Woo d r u ff
January 11

, 2 0 1 3

P age 2

We a r e r e q u est i n g WS assi s t a n ce w ith w o l f

- l i ve s t ock c o nfl i c t m a n ag e m ent because we do n ot

h a ve t h e ca p aci t

y to ad e q u a t e l y a ddr ess t h e l ev e l of confli c t we h ave a l r e a d y exp e r i e n ced

. We

an t i cipate c o ntin u ed r a pid g r o w th of Was h i n g t o n ’ s w o l f p o pu l a t i o n a nd w it h o ut y o ur h e l p
,

we w ill n o t b e a b l e t o a d e q u ate l y a ddr ess o r m a n age c o nfli ct s

. I f we a r e u n a b l e t o ad e qua t e l y

m anage c o nfl i c

t s, pub l i c t o l e r a n ce for w o l ves w ill d e c li n e a nd r e cov e r y eff orts c o uld b e j e o p a rd i z e d. W h i l e WDFW w o uld s ti ll p r o v id e n ecess a r y r

e m ova l s of w o l ves in t h e abs e n ce

o f a ddit i o n a l WS as s i s t a n ce, WDFW w ill n ot b e a b l e t o r esp o nd as effi c i e ntl y t o p o t e nt i a l o r

a c tua l d e p r

ed a t i o n ev e n t s a nd th u s p r o d u c e r s m ay s uf

f e r g r e a t e r l e v e l s of damages.

Addit i o n a l l y, w it h o ut y o ur pr o g r a m ’ s ex per t as s i s t a n c e
, W D FW wou ld pro b a b l y n e e d t o
redir e c t p e r s o nn e l from overa ll c o n s e r v a t i o n a nd recovery to f ocus o n r e s p o ndi n g t o d a m ages.

For t h ese r eas o n s
, wi t h o ut t h e as s i s t a n ce o f y o ur p r o g r a m
, ov e rall c o n s e r va t ion and r ecov e r y

m a y b e h a m p e r e d

.

One of t h e l e

ss o n s we l ea r n ed th i s ye a r i s t h e n e e d t o a nt i c i pa t e c o nfl i c t s r a t h e r than j u s t

r e s pond to re p o rted depredations. We w a nt t o b e w o r k i n g w ith li ve s tock p r od u c e r s proact i v e l y

n e x t s p ri n g and u s i n g techn iq u es to minimize c o nfl i c t s r a t h e r than r e s p o nding t o esc a l a ti n g
de p r e d at i o n ev e n t s. Th i s pr o act i ve a ppro a c h s h o uld h e lp u s minim i ze t h e number o f l e t h a l

r e m ova l s n ecess a r y a n d h o p e f ull y c o mpl et e l y av o id the n e e d for the r e m ov a l of an e ntir e p ack.

WDFW s t affi n g l eve l s and r es o u r ces a r e n o t a d e q u a t e f o r s u c h a c o mpr e h e n s i ve p r oa c ti v e

a p p r oach, ev e n a t c ur r e

nt w o l f p o p u l a ti on l ev e l s. T his s h o rt f a ll w ill b ec o m e ev e n w o r se w ith t h e

a n t i cipa t e d g r o w t h of W a s hi n g t o n ’ s w o l f p o pul a t i o n during t h e coming ye a r.

We a r e l o o k forw a rd to w orking wi th WS in com p l e ti n g t h e environmental asses s m ent a nd

in imple m en ti n g Wash i ngton ’ s Wolf C o n s e r v a t i o n a nd M a n ag e m e nt P l a n. We fee l t h ese a r e imp or tant s t eps f

o r r ecov e r y of s u s t a i n a b l e w o l f p o pu l a t i o n s in th i s s t a t e.

S i n c e r e l y,

N a t e Pam

p li n
, A s s i s tant Di r

e c tor

W ildl i fe P r ogr a mAPPENDIX 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

- WILD I FE

SERVICES

And The
USDA, FOREST SERVICE

NATIO NAL FOREST SYSTEM

This MEMORANDUM OF UNDERS T AND I NG is hereby made and entered into by and

between USDA, Animal and Plant Health Inspection Service

- Wildlife Services

, hereina f ter
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 ar e agencies of the United States Depart m e nt 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 du e 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 dam ag e to timber stands b y 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 AC TI VITIES ON NATIONAL

FOREST SYSTEM LANDS

I. PURPOSE:

The purpose of th is agreement is to document the cooperation between the parties: ( 1)

to id e nt ify 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 ve rt ebrates 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 an d APHIS

WS; 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, pe rmittees

, and

others. Wit h the U.S. Forest Service, identify human health and safety zones and

other areas where mitigation or restriction of WD M activities may be needed to comply with f

orest plans.

C. Be responsible for NEPA compliance for wildlife damage

, invasive and wildlife

disease management activities initiated by APHI S

- 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 comple ting the NEPA process for

such activit ie s. The FS will be responsible for NEPA com pliance for any WDM

activities not covered above.

D. Notify the U.S. Forest Service about WDM requests prior to the execution of WDM

activit ies

.

E. Inform the U.S. Forest Service about the results of WDM activities initiated by APHIS

- WS in a time ly manner. 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 tool s 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 APH I S

- 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 com pliance 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 MUT UAL L Y 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 S tat. 1329

- 331, 7 U.S.C. 426c) to provide WDM services. This includes

m aintaining technical expertise in the science of WDM control tools and techniques, conducting WDM research, conducting m anagement progra ms
, conducting wildlife

disease surveillance

, and complying with NEPA requirem ents for WDM.

C. All WDM programs on NFS lands will be coordinated with appropriate State

, Tribes

, and Federal agencies prior to implementation of these program s.

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 Depart mental Regulation 9500

- 4), U.S. Forest Service policies

, and applicable forest land a nd resource management plans.

E. Parties will comply with all applicable Federal

, State

, and local laws and regulations

in the us e and application of pesticides.

F. State WDM agreements will be developed, as needed with the appropriate State, Tribes,

and Federal agencies.

G. Both part ies 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 Ad m inistrator 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. Problems regarding 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 toAPPENDIX 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, a nd fact- finding.

K. The Parties will cooperate on WDM research of mutual interest.

L. The parties shall 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 parties require 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 CON T ACTS. 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 R d

. , 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 Av e

. , 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 Comm unications. A written request must heAPPENDIX B

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 73 submitted and approval gr a nted 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. NONDISCRIMINATIO N STATEMENT

- PRINTED, ELECTRONIC, OR

AUDIOVISUA L MATERIAL . APHIS

- WS sha ll 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 prohibite d 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 em ployer."

If the material is too small to permit the full statement to be included, the material

must, at minimum, include the following statement, in print size no smaller than the

text:

''Th is institutio n is a n 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 l aw or equity. The parties sha ll

manage their respective resources and activities in a separate, coordinated and mutually

beneficial manner to meet the purpos e (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

, prop ert y
, 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 meets these criteria. If the parties elect to enter into

an obligation instrument that involves the transfer of funds

, services, propert y, and/orAPPENDIX B

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 74 anything of value to a pa rt y, then the applicable criteria must be met. Additionally,

under a prospective instrument, each party operates under its own laws, regulations.

And /o r policies

, and any Forest Service obligation is subject to the availability of appropriated funds and other resources. The negotiation, execution, and

a dministration of these prospective instruments must com ply with all applicable l aw

.

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 lntragove rn mental Disputes and Major Differences” ).

T. MODIFIC A TIONS. 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 im plication 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 transmi tte d 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 fro m 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.APPENDIX B

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 75 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 em ployment to the extent compe nsation is available pursuant

to the Federal Tort Claims Act (FT CA). 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 FT CA and applicable regulations.APPENDIX B

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 76APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 77 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 Me thods 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. F inal 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. R isk 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 r esource 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 no t 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." B ecause many of the remaining wildlife management methods may result in injury o r 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 s tates that used APHIS WS's

Managem ent 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 env ironmental 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 th e 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 met hod. Because many animals are released, potential risk may be

overestimated.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 78 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 rec ords

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 infor mation 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 req uiring 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 i n 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 alternat e 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 occ upation. 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. F rig h te n i ng Dev i ces (1) U se 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.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 79 (2) Hazards

Human Health and Safety

The use of harassment devices may affect human health and safety due to auditory and visual

disturbances.

Envi ronmental

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 Relocati on Met hods (1) Leghol d T raps
(a) Descri ption 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 N o.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 toAPPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 80 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) Hazard s
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 forAPPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 81 the six MIS states indicates five injuries to APHIS WS personnel related to use of leghold traps
in 1 988.

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 1 988, the six MIS states reported a total take by leghold traps of 21

, 992 animals. Of these,

16,865 were target animals and 5

, 1 27 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.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 82 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. Sli ght 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 d evices 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 ex posure 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 anim al's attraction to baits within the trap, trapAPPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 83 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 severa l 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 pri marily 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 s pecies 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 t he 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 suburba n areas and on publicly

- owned properties.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 84 (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, plac ing, 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 trap s 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 whic h 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 t o 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

associat ed 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 minim al 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 ar e 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.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 85 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 w ith one or more swivel s to minimize cable twisting and breakage. Snares are designed to tighten a round 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

horizonta lly 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 translocati on 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 e xit 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 nation

wide in the APHIS WS program. Dependent upon snare type and circumstance, use may occur in rural or urban areas and on privately or pu blicly

- 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

sp ring 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 gener ally 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.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 86 (c) Risks Human Health and Safety Risk of human injury by snares is genera lly 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 assista nce. 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 minimiz ed 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 th e 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 dev ices 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 tak e 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 directio n 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 thi s method in the six MIS states in 1988 were coyotes, beaver, and blackbirds. S hooting was also used in wildlife damageAPPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 87 control operations in APHIS WS programs other than in the six MIS reporting states. It is also employed to humanely destroy animals cap tured 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 withou t proper

h earing 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

Envi ronmental 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 Safe ty 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 practi ces. 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.

Environme ntal 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 damag e 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 o f shooting.APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 88 (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 i n 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 greate r 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 gun ner. 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 firear m 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 spe cific target animals. Hazards to nontargets are confined to animals that may be mistakenly identified or those which inadvertently enter the path of fire during harassmentAPPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 89 activities. Localized environmental hazards associated with aircraft crashes inclu de 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 elim inates 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 APH I S WS program use of aircraft in 6,000 aerial hunting and hazing operations in 1988. I n 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) di scussed 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 traini ng 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 mu st 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 establi shed 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 publ ic. 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.

Environm ental 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 high ly 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).APPENDIX C

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 90 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 nontarg et 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 sc oring 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 p robable risk is expected because affected animals are immediately

removed.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 91 Appendix D: Summary of Public Comments and Responses on the December 2013 Pre

Decision Environmental Assessment Wildlife Services’ Gray Wolf Damage Managemen t 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 effect s 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/

conse rving 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 non

targets, whether WDFW or WS conducts the trapping/removal, is expected.

Under the Proposed Action A lternative, 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, p lanned activities must be included in work plans developed

in coordination with each National Forest or BLM Resour ce 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 p ublic 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 cont rol 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

dea dly wolf attack in Saskatchewan in 2005 and another in Alaska in 2010. T here 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 preferre d 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 pub lic 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 forAPPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 92

providing the requested assistance to WDFW and USFWS and possible requests from T ribes 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 go vernment 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). Se ctions 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 request s 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 re sponsible 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 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 W S 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 sol ve 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 consideratio ns. 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 non

lethal 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 managem ent 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 t o 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 beAPPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 93

made in this EA is whether WS should provide t he requested assis tance 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 industry

wide, 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 und erestimate 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 A lternative pertains to al l 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

condu cted if a request for assistance is received from the agency responsible for managing the land in question. W S 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 Washing ton. 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

m ortality, 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 expect ed 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 re spond 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 througho ut the EA, incorporate data and actions from outlying states in Population Viability Analyses and modelling conducted by Washington State University. T he determination to be made is whether WS' actions

would result in differences from Agencies/Tribes taki ng 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 alternativ e

.

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 seri ous negative effects of killing large
numbers of wolves or the positive ecological effects associated with wolf recovery”.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 94

Alternative 2 was to eliminate WS from assisting in all forms of wolf management, which would be letting nature balance and self

- regu late. 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

man agement 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 “ n o 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 ce rtain 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

age ncies, wolf populations in those states continued to expand and increase (EA Chapter 1,

Introduction ) , Bradley (2004), USDA (2011 a ) , and USDA (201 1b ) , in fact, well beyond original population goals set for recovery. There is no reason to believe that simi lar 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. T he 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 s ignificant 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 investigato rs to make erroneous findings.

WD FW and USFWS asked WS to provide assistance in conducting wolf depredation inv estigations.

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 mana gement 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 a vailable 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 compensatio ns 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 pre dator 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 killingAPPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 95

livestock in 2005, 117 investigations and confirmed 54 in 2006, and 128 investigations and confirmed

74 in 2 007. 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 dep redation 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 tha n would WS agents that bring unnecessary negative political baggage with
them to an already controversial wildlife issu e.

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 ne w 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 assis tance with wolf damage management. WS is well

qualified 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 investigati ons 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. A uthority 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 i n 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 FEI S 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, questio nable 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 un biased role in wolf management in Washington

– or anywhere

– and that its involvement thus far has greatly undermined gray wolf recovery
throughout its historic range.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 96

WS disagrees with this statement. The commenter's claim that WS participated in illegal attempts to kill federally endangered wol ves 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 discus sed throughout the EA, the responsible wildlife management agency ( WDFW, USWFS ) or sovereign tribal government would make determination s on wolf removal, not WS.

WS also disagrees with the comment that it is biased and its involvement has undermined wol f recovery in other states. E ven though WS has removed wolves in other states, at the request of state and federal management agencies, wolf populations in those states continued to expa nd and increase
[ EA Chapter 1, Introduction , Bradley (2004), USDA (20 11 a ) and USDA (201 1b ) ] , 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 ac curately 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 predat or damage to livestock. Stone (2009) further stated that WS livestock depredation investigati ons resulted in a finding of "probable" in

102 investigations conducted between 1987 and 2009, rather than a finding of “confirmed” in every investigation

. The I daho 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 w olves killing livestock in 200 5; conducted 117 investigations and confirmed 54 in 2006 ; and conducted 128 investigat ions 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 shou ld follow a protocol th a t 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 Washing ton 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 appl ied. 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 researc h, conducting management programs, conducting wildlife disease surveillance, and complying with NEPA requirements for wildlife damage management

. WDFW has

th e regulatory authority to manage federally de

- listed wolves in WA and may assist USFWS when

reques ted 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 wol ves 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 E SA. The decision to delist federal species is the responsibility of the USFWS. The decision to delist state species is the responsibility of each state.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 97 11) Some comments questioned whether removing depredating wolves aided in building public

tolerance/c ons ervation 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 wol ves 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, non

lethal options, and letha l 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 tran sition 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 w ere 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 wol f 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

manage ment 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 the y are federa l ly

- 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.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 98 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 method s 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). Pertin ent discussions from Appendix P were added to the EA as A ppendix C . The

EA is a stand

- alone document, thus readers wi ll not need to ref er 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 man agement.

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 long

term 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. Th e 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 eff iciently 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 w olves. 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 conservat ion 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 incorporat e new tools entering the marketplace that provide added benefit. Impacts to wolves and non

- target animals

were t horoughly 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 ( page s 23

- 24 of the EA ) , and WS would monitor foothold traps or snares every 24 hours while using them (page 30 of the EA)

.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 99

g. Public sentiment i n 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 t o 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

trapp ing of problem/dangerous wildlife . The Washington State D irector of Wildlife is authorized to grant special p ermits to use traps in responding to animal problems that have not and cannot be reasonably abated by the use of non

- letha l control tools. Further, the D irector may grant special permits to department employees or agents where the use of the traps is the only practical means of protecting threa tened 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 o r not.

14) Some commenters cited published literature to suggest that r emoval of wolves does not reduce
depredation

. The y 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 b y 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. (2 012) 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 wi ll 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 (2 005) 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 ani mals (Meadows and Knowlton 2000 ), or scar e 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 o f 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 chapt er 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 an d elsewhere will be directly compa rative to reducing conflict..."APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 100 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 e ffect 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

inten sity 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 ( WCMP W ) (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

inten s ity of the actions was also considered in the NEPA process. Specific issues that were determined to be impor tant 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 loc al laws, among other issues. Section 3.2 lists aspects of the human environment that would not be affected and why. Section s 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. A ll 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 t he 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 controv ersial (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. "O pposition and a high degree of controversy . . . are not synonymous." 6 The effect s of let hal control actions are not controversial among agency

researchers and experts inv olved 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 population s have expanded and their

distribution and numbers have exceeded pred ictions (USFWS 1994, USFWS et al. 2007, 2008, 2009, 2010). 4) highly uncertain or unk nown 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 responsibiliti es).APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 101

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 wi l l 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 appl icable 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 su pport 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. L ethal 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 W ildlife Services’
predator control programs by professional societies including the American Society of
Mammologists and The Wildlife Society.

T he 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 P age 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. (2 012) reported that research must be framed with realistic expectations. Th e 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 becau se 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 d evices (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 2 012, 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 con ditions 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 be low

cost 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 theAPPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 102

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 age ncy takes action.

Under the Proposed Action A lternative, 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 entit ies that determine whether and how many wolves will be trapped, removed, or

collared. This de termination 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 WDF W 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 re gards 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 P roposed A ction Alternative as discussed in Chapter 1, Section 1.2, and Section 2.1. Nonlet hal measures are already required by t he 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 s hould 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.

Thi s 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 P roposed A ction Alternative. Nonlethal measures are already required by t he 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 evalu ated

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 consi derations. 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".

Am ple 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

.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 103

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, " ...l ethal 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 fee ding 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 n on
- 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 altern atives would be similar to the Proposed A ction Alternative (Sec tion 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 se t by WS personnel. WS WA has not unintentionally capture d 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’ consul tation 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 Novem ber

- 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 reportin g 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 t he 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 employe es 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.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 104

WS comp lies 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 wol ves 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 non

target wildlife be taken t o 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 prot ected, 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 repo rt the results of its action s to the responsible land/resource management agency (WDFW, USFWS, or Tribes) requesting the service from WS Section 2.3 of the EA)

.

T rapping allows for the release of non

- target animals (page 23 of the EA) . WS WA’s non

- targ et 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 (p age 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 wol ves 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 occasio ns 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 conduc ted 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 p redation 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 a ny 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 an imals, 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

recreati onal 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.APPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 105

WS has the federal expertise and authority, under the Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C.

4 26

- 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. T he Proposed Action

A lternative 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/ranc hers? 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

W ashington by conducting trapping and removal o f 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 t he 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 non

l ethal 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 wo uld 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 t he 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 a n 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 t o 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 wou ld 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 effe cts 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 statewi de 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 publ ic 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 is sues 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 ed its 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 , p age 5 : The reader is [led] to believe that all cattle deaths are related to wolf
kills. All predators (such as: g rizzly b ear; c ougar; c oyotes; and h umans), can kill cattle along

with natural deaths or accidents. O nly 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 hav e 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 confi rmed 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 question ed 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 a ny way; rather it is expressly identified so the reader can understand the thought process WS uses in determining action strategies.

22) On commenter sug gested 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. Steril izing 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 is sue permits to trap entire packs and then hold those packs in captivity.

23) One commenter requested that we “p lease describe Wildlife Services (WS) successes and failures as they
relate to Gray Wolf damage in MT, ID and WY. Please include reasons for the s uccesses 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 depre dations 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 o f 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 la nd for several generations now.

b. What is the relationship between the National Rifle Association and Wildlife Servi ces?

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 an d 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 spra wlAPPENDIX D

Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington 108 Literature Cited

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