### Pre

- decision 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

December 16, 201 3Table of Contents 1

2

List of Acronyms and Abbreviations

................................ ................................ ................................ ........................... iii 3

EXECUTIVE SUMMARY

................................ ................................ ................................ ................................ .......... iv 4

CHAPTER 1. PURPOSE AND NEED FOR ACTION

................................ ................................ ................................ 1 5

Introduction

................................ ................................ ................................ ................................ ............................... 1 6

1.1 Purpose

................................ ................................ ................................ ................................ ................................ 4 7

1.2 Need for Action

................................ ................................ ................................ ................................ ................... 4 8

1.3 Scope of Analysis

– Location and Actions Analyzed

................................ ................................ .......................... 7 9

1.4 WDFW Wolf Management Goals

................................ ................................ ................................ ..................... 10 10

1.5 Period for which this EA Remains Valid

................................ ................................ ................................ ........... 11 11

1.6 Decision to be Made

................................ ................................ ................................ ................................ .......... 11 12

1.7 Summary of Public Involvement Efforts

................................ ................................ ................................ ........... 11 13

1.8 Relationship of this EA to other Environmental Documents

................................ ................................ ............. 12 14

1.9 Authority and Compliance

................................ ................................ ................................ ................................ . 13 15

1.9.1 Authority of Federal and State Agencies in Wolf Damage Manag ement

................................ ................... 13 16

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

................................ ................. 14 17

CHAPTER 2. DESCRIPTION OF ALTERNATIVES

................................ ................................ .............................. 18 18

2.1 Alternative 1

- No Action

................................ ................................ ................................ ................................ .. 18 19

Non

- lethal Methods Available to WS, WDFW, USFWS, Tribes

, and the Public

................................ ............... 21 20

Non

- lethal Methods Available to WDFW

, USFWS

, and Tribes, but not WS

................................ ..................... 23 21

Non

- lethal Methods which may Require Special Authorization from WDFW, USFWS, and Tribes

................. 24 22

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

................................ .... 25 23

Monitoring

................................ ................................ ................................ ................................ ........................... 26 24

2.2 Alternative 2

– Eliminate the Current Wolf Assistance Program

................................ ................................ ...... 26 25

2.3 Alternative 3

– Proposed Action

– Expand the Current Wolf Assistance Program

................................ ........... 27 26

Formulating a strategy for wolf removal

................................ ................................ ................................ ............. 28 27

Description of Lethal Methods Avai lable to WS

................................ ................................ ................................ . 28 28

Measures used by WS to Minimize Environmental Risk

................................ ................................ .................... 30 29

Monitoring

................................ ................................ ................................ ................................ ........................... 37 30

2.4 Summary of Actions allowed by Alternative

................................ ................................ ................................ ..... 37 31

CHAPTER 3

- ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

................................ ........................... 40 32

3.1 Issues Driving the Analysis

................................ ................................ ................................ ............................... 40 33

3.2 Issues Not Analyzed in Detail, with Rationale

................................ ................................ ................................ .. 40 34

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

................................ ......... 43 35

3.3 Eval uation Methodology

................................ ................................ ................................ ................................ ... 44 36

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

................................ ................................ .......................... 45 37

4.1 Alternative 1

– No Action

................................ ................................ ................................ ................................ .. 45 38

4.1.1 Impact on wolf population

................................ ................................ ................................ .......................... 45 39

4.1.2 Impacts on non

- target animals and human safety

................................ ................................ ....................... 47 40

4.1.3 Social and Aesthetic Perspectives

................................ ................................ ................................ ............... 47 41

4.1.4 Effectiveness

................................ ................................ ................................ ................................ ............... 49 42

4.2

- Alternative 2

– Eliminate the Current Wolf Assistance Program

................................ ................................ .... 51 43

4.2.1 Impact on wolf population

................................ ................................ ................................ .......................... 52 44

4.2.2 Impacts on non

- target animals and human safety

................................ ................................ ....................... 52 45

4.2.3 Social and Aesthetic Perspectives

................................ ................................ ................................ ............... 53 46

4.2.4 Effectiveness

................................ ................................ ................................ ................................ ............... 53 47

4.3 Alternative 3

– Proposed Action: Expand the Current Wolf Assistance Pr ogram

................................ ............. 53 48

4.3.1 Impact on wolf population

................................ ................................ ................................ .......................... 54 49

4.3.2 Impacts on non

- target animals and human safety

................................ ................................ ....................... 55 50

4.3.3 Social and Aesthetic Perspectives

................................ ................................ ................................ ............... 57 51

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington i4.3.4 Effectiveness

................................ ................................ ................................ ................................ ............... 58 1

4.4 Summary and Conclusions

................................ ................................ ................................ ................................ 59 2

CHAPTER 5

– Literature Cited

................................ ................................ ................................ ................................ ... 60 3

Appendix A: WDFW Letter

................................ ................................ ................................ ................................ ....... 67 4

Appendix B: 2011 MOU between WS and USFS

................................ ................................ ................................ ...... 69 5

Appendix C: Summary of Public Comments

................................ ................................ ................................ .............. 77 6

7

8

9

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- Wildlife Services’ Gray Wolf Damage Management In Washington ii

### List of Acronyms and Abbreviations 1

APHIS Animal and Plant Health Inspection Service (USDA agency) 2

AVMA American Veterinary Medical Association 3

BLM Bureau of Land Management (USDI agency) 4

CEQ President’s Council on Environmental Quality 5

CFR Code of Federal Regulations 6

EA Environmental Assessment 7

EIS Environmental Impact Statement 8

EJ Environmental Justice 9

EO Executive Order 10

ESA Endangered species Act 11

FR Federal Register 12

MIS Management Information System 13

MOU Memorandum of Understan ding 14

NEPA National Environmental Policy Act 15

NHPA National Historic Preservation Act 16

NRM DPS Northern Rocky Mountain Distinct Population Segment 17

RAG Radio Activated Guard 18

RCW Revised Code of Washington 19

T&E Threatened and Endangered 20

USC United States C ode 21

USDA United States Department of Agriculture 22

USDI United States Department of the Interior 23

USFS United States Forest Service (USDA agency) 24

USFWS United States Fish and Wildlife Service (USDI agency) 25

WAC Washington Administrative Code 26

WCMPW Wolf Con servation and Management Plan for Washington 27

WDFW Washington Department of Fish and Wildlife 28

WDM Wildlife Damage Management 29

WS Wildlife Services (USDA

- APHIS program) 30

31

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- Wildlife Services’ Gray Wolf Damage Management In Washington iii

### EXECUTIVE SUMMARY 1

2

This environmental assessment (EA) evaluates a proposed action and alternatives to ass ist the 3

Washington Depart ment of Fish and Wildlife ( WDFW ) , the United States Fish and Wildlife 4

Service (USFWS), a nd Native American tribal governments with management of gray wol f 5

( Canis lupus ) conflicts throughout the s tate

. The n eed for action is based on confirmed and 6

repeated livestock depredation , expectations of increases in damages as the wolf population 7

increases and expands in WA, and the potential for wolves to threaten human safety. The actions 8

to protect livestock are i mmediately necessary where the gray wolf population is managed by 9

WDFW

. Assistance to WDFW may include technical assistance, harassment, lethal removal, 10

live

- trapping, collaring, translocation, and monitoring wolves. USFWS may authorize WDFW 11

to conduct nonlethal wolf management (e.g., live

- trapping, collaring, translocating wolves for 12

study , or hazing ) in portions of the state where wolves are protected under the Federal 13

Endangered Species Act (ESA). When this occurs, WDFW may request the United States 14

Department of Agriculture, Wildlife Services (USDA) to assist. USFWS may also directly 15

authorize United States Department of Agriculture’s (USDA) Animal and Plant Health 16

Inspection Service (APHIS) Wildlife Services ( WS ) to provide assistance with nonletha l wolf 17

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

. 18

19

Legal status of wolves in Washington 20

21

The most pertinent and recent 22

regulatory action was a 5 May 2011 23

federal delisting of wolves from the 24

federal Endangered Species Act 25

( ESA ) in eastern Washington

, w hich 26

will not be subject to judic ial review 27

(76 FR 25590; 5 May 2011, as 28

mandated by Public Law 112

– 10). 29

Under this rule, wolves were 30

federally delisted in Washington east 31

of Highway 97 from the British 32

Columbia border south to Monse, 33

Highway 17 from Monse south to 34

Mesa, and Highway 395 from Mesa 35

south to the Oregon border, but 36

remained federally listed west of 37

these highways (Figure 1 ) (74 FR 38

15123; April 2, 2009). This boundary 39

falls within WDFW’s east ern wolf 40

management zone. 41

42

Wolves in the eastern third of Washington within the Northern Rocky Mountain Distinct 43

Pop ulation Segment (NRMDPS) boundary are federally delisted and now managed by WDFW 44

or

, for those lands of Indian Nations which are identified as reservation lands, by the sovereign 45 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

.

Pre

- decision Environmental Assessment

- Wildlife Services’ Gray Wolf Damage Management In Washington ivtribal authority. Gray wolves are currently classified as endangered under Washington state law 1

t hroughout the state (Washington Administrative Code 232

- 12

- 297 ). Ba sed on the expected re

2

estab li shment of wolves in Washington

, WDFW developed a Final Recommended Wolf 3

Conservation and Management Plan for Washington (WCMPW) on 28 Jul y 2011 4

( http://www.wdfw.wa.gov/publications/00001/ ) to meet the requirements of the Washington 5

ESA. The WCMPW was adopted by the Washington Fish and Wildlife Commission on 3 6

December 2011. It “.

. . provides recovery goals for downlisting and delisting the species and 7

prescribes strategies to achieve these goals, including management of conflicts with livestock 8

and ungulates ” ( Wiles et al. 2011 ). 9

10

Gray wolves are expected to continue to increase in number in Washington. Outside of the 11

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

, wolves r eceive additional 12

protections under the federal ESA where they are currently federally classified as endangered (74 13

FR 15123; April 2, 2009). Wh ere gray wolves are federally listed (those portions of Washington 14

west of the NRMDPS line)

, t he U.S. Fish and Wildlife Service is the responsible federal agency 15

for regulatory compliance for any management decisions affecting wolves

. On 7 June 2013, the 16

U.S. Fish and Wildlife Service announced the release of their proposal to delist Gray wolves in 17

Washington and elsewhere. The proposed rules were published in the Federal Register on 13 18

June 2013. The Fish and Wildlife Service welcome d publ ic comment for 90 days from the date 19

of publication. If federal delisting occur s , gray wolves throughout the State would be managed 20

according the WCMPW ( Wiles et al. 2011 , or as amended)

. Again, the exception to state 21

management authority would be those lands managed under sovereign tribal authority. 22

23

Need for Action 24

25

The increasing presence of wolves in Washington initiated a need to mitigate and resolve 26

conflicts when wolves cause harm to livestock. This EA discusses the direct and indirect effects 27

of w olf depredation on livestock and public safety throughout Washington . The first likely wolf 28

depredation on livestock was reported in Stevens County in September 2007. M ore recent wolf 29

attack s on livestock w ere confirmed July through September 2012

, in north eastern WA

. 30

Between August and September 2012, WDFW killed seven wolves from the Wedge Pack, 31

including the alpha male and female, i n order to reduce wolf predation on livestock and “reset 32

the stage for sustainable wolf recovery in this region” (W DFW Director Phil Anderson, 33

http://www.wdfw.wa.gov/news/sep2712b/ ). 34

35

The number of documented livestock killed by wolves to date in Washington may represent a 36

minimal number, with more livestock kills probably going unconfirmed. Lethal control of 37

wolves may be necessary to resolve repeated wolf

- livestock conflicts and would be performed to 38

remove problem animals that jeopardize public toler ance for overall wolf recovery ( Wiles et al. 39

2011 ). Wolf control may also be conducted to protect public safety. W DFW has requested WS 40

to assist so WDFW personnel may focus their efforts on conservation and recovery instead of 41

capture or removal. 42

43

44

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington vActions Analyzed 1

2

Wildlife Services (WS) p roposes to assist WDFW , USFWS, and tribes with resolving gray wolf 3

damage, as requested by WDFW unde r WAC 232

- 1 2

- 297 and the WCMPW or similar guidance

. 4

Act ions would include assist ing WDFW to reduce wolf conflicts to protect livestock, includ ing 5

herding and guarding dogs, and human safety, as defined in WCMPW ( Wiles et al. 201 1 )

. WS 6

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

, provid ing a 7

variety of non

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

8

capture, monitoring), and public education

. At the request and direction of WDFW

, WS may 9

lethally remove de

- listed wolves from packs ident ified as being involved in repeated livestock 10

depredations

. 11

12

At the request of USFWS

, or WDFW acting as an authorized agent of USFWS, WS may take 13

nonlethal actions (e.g., live

- capture, monitoring) towards federally listed wolves . However 14

under certain extenuating circumstances, lethal actions may be necessary in defense of human 15

safety or for euthanasia in accordance with ESA guidelines 1 a nd Code of Federal Regulations 16

(CFR) 2 . O n tribal lands

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

. 17

All assistance provided by WS would comply with the WCMPW or similar guidance. 18

19

Alternatives 20

21

A “ N o A ction ” alternative was evaluated for comparison to describe the environment al baseline. 22

“No Action” refers to maintaining the current WS Wolf Assistance Program, which provides 23

technical assistan ce and non

- lethal direct control. If WS continued with the existi ng program 24

(“No A ction ”)

, WDFW would implement the WCMPW to the best of its ability, including lethal 25

control of wolves ( Appendix A ). The Eliminate the Current Wolf Assistance Program 26

alternative would prevent WS from conducting any wolf damage management, providing any 27

technical assistance, or assisting in public edu c ation and outreach of wolf issues. The Proposed 28

alternative , Expand the Current Wolf Assistance Program, would allow WS to respond to 29

requests from WDFW , USFWS, and tribes to assist with several aspects of the WCMPW, 30

including lethally removing problem de

- listed wolves at the request of WDFW or tribes as part 31

of WDFW/USFWS overall conservation and recovery. 32

33

34

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).

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington viEnvironmental Consequen ces 1

2

The Proposed A lternative was examined to identify potential effects on the Washington wolf 3

population

, including the potential for wolf recovery and State ESA delisting

. The EA examine d 4

the effects on n on

- target animals

, human safety, and on social and aesthetic perspectives 5

including public acceptance, human e ness

, and aesthetic enjoyment of wolves . The effectiveness 6

of the alternatives in me eting the purpose and need and how well the alternatives alleviate 7

livestock damages is also discussed

. Th is EA found that there would continue to be a growing 8

wolf population in Washington if the proposal is adopted, and it would likely have no or very 9

few negative effects on other animals and humans

. 10

11

WDFW indicated that if Wildlife Services does not adopt the Proposed A lternative, necessary 12

lethal actions would be implemented by the State of Washington , or its agents, as is 13

demonstrated and discussed in the EA , WCMPW, and under the same strict guidelines as 14

allow ed by WDFW (Appendix A ). WDFW further indicated that increased livestock losses 15

would likely occur , more wolves might be removed, and WDFW’s overall wolf conservation 16

efforts in Washington would be challenging without the assistance of the WS program (i.e., 17

under the No Action or Eliminate the Current Program alternatives). 18

19

A No Action a lternative (continue the current program of non

- lethal and technical assistance 20

only) was evaluated in detail. Social perspectives were similar between the No Action and 21

Proposed Action alternatives. Some members of t he public might prefer the No Action 22

altern a tive because WS would not kill any wolves , b ut WDFW, or its agents, would still remove 23

problem wolves as allowed under the WCMPW ( Wiles et al. 2011 ) and state law (RCW 24

77.12.240) whether or not WS assisted. Ther e could be negative environmental consequences if 25

private citizens were allowed to lethally control wolves , rather than state or federal wildlife 26

professionals because it is open to abuse when conducted by the public, thereby requiring law 27

enforcement foll ow

- up (Bangs et al. 2006). If WS was not allowed to provide any technical 28

assistance or public education/outreach, wolf depredation may increase, which could result in a 29

need to lethally remove more wolves. Requiring WDFW to devote its staff time towards lethal 30

wolf control would detract from the time those personnel could devote to wolf conservation 31

( Appendix A

, letter from WDFW)

. 32

33

T he Eliminate the Current Program alternativ e would prevent WS from providing any direct or 34

technical assistance to WDFW, Washington citizens, and other public and private 35

agencies/corporations in Washington. WDFW stated if WS did not assist with wolf depredation 36

management, they would conduct the removals themselves. If WDFW professionals conducted 37

wolf removal, there would be little difference in the environmental effects , except that wolf 38

recovery may be hampered and possibly more wolves would need to be removed due to fewer 39

efforts directed at proactive and preventative measures (Appendix A) . But, there could be negative 40

environmental consequences if private citizens were allowed to lethally control wolv es, rather than 41

state or federal wildlife professionals. If WS was not allowed to provide any technical assistance or 42

public education/outreach, wolf depredation may increase, which could result in a need to lethally 43

remove more wolves. WDFW indicated th at it would be required to direct staff time towards 44

responding to damages which would detract from wolf conservation and recovery (Appendix A)

. 45

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington viiCHAPTER 1. PURPO SE AND NEED FOR ACTION



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

2

Introduction 3

4

Historically, gray wolves ( Canis lupus ) were found throughout most or all of Washington before 5

1800. They were essentially extirpated from the state by the 1930s 6

( http://wdfw.wa.gov/conservation/gray_wolf/ ) through trapping, the use o f toxicants, and 7

shooting. The USFWS successfully reintroduced gray wolves into Idaho and Yellowstone 8

National Park in 1995. From that, the wolf population in the northwestern United States 9

increased substantially , leading to an expanded presence of wolves in Washington since 2002. 10

Dispersal of wolves into Washington from British Columbia, Idaho, Montana, and Oregon has 11

resulted in resident breeding population. 12

13

The gray wolf is listed as an endangered species throughout Washington under state law (WAC 14

232

- 12

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

- thirds of 15

Washington. Wolves in the eastern third of Washington were removed from federal listing in 16

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

. 17

18

Managing human/wolf conflicts is an integral part of wol f management in Washington where 19

e mphasis is placed on goals and objectives that the Washington Department of Fish and Wildlife 20

(WDFW) adopted in the Wolf Conservation and Management Plan for Wash ington (WCMPW) 21

( Wiles et al. 2011). The WCMPW put forth strategies to minimize wolf conflicts by 22

incorporating conflict avoidance

, information

, education , and limited lethal removals when 23

repeated livestock depredations occur. The WCMPW defines “livestock” to mean: cattle, calves, 24

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

. The WCMPW 25

also allows for responding to potential threats to human safety. 26

27

The WCMPW was initiated in 2011 to address the i nevitable need to manage wolves in the state. 28

The WCMPW would also serve the State’s legal obligations under the Washington ESA (WAC 29

232

- 12

- 297). 30

31

Although livestock losses to wolves are minimal industry

- wide, losses to individual operators 32

can be signifi cant (Fritts et al. 1992, Mack et al. 1992). Control of offending wolves, along with 33

increased livestock management practices ( e.g ., carcass management, fencing, etc.), 34

compensation for losses, and communication with the public have all contributed to wol f 35

recovery where wolf

- livestock conflicts exist (Fritts et al. 1992, Mack et al. 1992, Niemeyer et 36

al. 1994, Bangs et al. 2006). 37

38

As of November 2013 , there were ten confirmed packs in Washington : seven packs in the 39

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

, 40

and none in the South Cascades & Northwest Coast management zone (Figure 2). There are also 41

two suspected pack s in the Eastern Washington management zone and t wo packs bordering 42

Washington ( one near Walla Walla and another in the north Cascade Mountains). Two solitary 43

wolves occur in northeastern Washington. 44

45

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 1CHAPTER 1. PURPOSE AND NEED FOR ACTION

1

WDFW r equested that APHIS, Wildlife Services (WS ) assist with managing gray wolf damage 2

to livestock and potential risks to human safety, as defined in WCMPW

. A s wolves become 3

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

. The 4

reason WS is req uested to assist in these case s is because WS has special expertise in evaluating 5

and confirming livestock depredation , technical expertise in non

- lethal methods to minimize 6

wolf damage

, expertise in live

- capturing for radio collaring /monitoring

, and remo ving 7

individual de

- listed wolves responsible for depredation or that are deemed to be threats to 8

livestock /public safety . WS also has personnel to provide wildlife damage management 9

assistance, as well as aircraft and pilots/crews, and is readily suited to providing the requested 10

assistance in an efficient and effective manner

. 11

12

The proposed action would predominantly occur where gray wolves are not federally managed 13

within Washington’s portion of the Northern Rocky Mountain Distinct Population Segment 14

bo undary 3 (NRMDPS) ( Figure 1). Gray wolves throughout Washington are protected under 15

State law as endangered ( WAC 232

- 1 2

- 297 ) , with three management zones having been 16

established by WDFW and Washington Fish and Wildlife Commission (Figure 2) . Therefore, 17

gr ay wolves in NRMDPS area of the State (a portion of WDFW Eastern management zone) fall 18

under the protection and management authority of WDFW

. WS may also respond to requ ests 19

from the USFWS and tribes regarding wolf damage management but does not anticipat e taking 20

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

.

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 2CHAPTER 1. PURPOSE AND NEED FOR ACTION

lethal actions for federally listed wolves

. 1

2

Recent Legal Status Changes 3

4

Wolves were absent from Washington for more than 30 years when they gained endangered 5

status in 197 3 with their listing under the federal ESA. In 1987, USFWS completed the revised 6

Northern Rocky Mountain Wolf Recovery Plan. Four years later Congress initiated an 7

administrative process to reintroduce wolves into Yellowstone National Park (YNP) and central 8

Idaho. In 1995 and 1996, 66 wolves were captured in Alberta and British Columbia, Canada. Of 9

those, 35 were released in central Idaho and 31 were released into Y NP

. Wolves were protected 10

as a “non

- essential experimental population” under the federal ESA within a specified zone that 11

included po rtions of Idaho, Wyoming

, and Montana

. 12

13

W hen t he WCMPW was initiated in 200 7 , gra y wolves in Washington were under the primary 14

jurisdiction of the USFWS and were federally listed as endangered under the federal ESA of 15

1973. On 4 May 2009, wolves in the NRMDPS (east of Hwy. 97/17/395 ) of Washington were 16

removed from the protections of the federal ESA ( Figure 1 )

. However, on 5 August 2010, federal 17

protections for wolves in the NRMDPS portion of Washington were reinstated, which meant that 18

all wolves in Washington were federally

- listed as endangered. 19

20

S ubsequently, on 5 May 2011, the USFWS published a final rule implementing Public Law 112

- 21

10, Section 1713, directing the Secretary of Interior to effectively delist wolves in the identified 22

NRMDPS, includ ing the portion of th at boundary identified in Washington (Figure 1) ( 76 FR 23

25590)

. That act of Congress changed the legal status of wolves in the eastern third of 24

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

. 25

T hus t he only protections in effect in this area are those established by State law under the 26

Washington Endangered Species Act ( WAC 232

- 12

- 297 ). On 7 June 2013, the U.S. Fish and 27

Wildlife Service announced the release of their proposal to delist Gray wolves in Washington 28

and elsewhere. The proposed rules were published in the Federal Register on 13 June 2013. The 29

Fish and Wildlife Service welcomes publ ic comment, which will be accepted for 90 days from 30

the date of publication. 31

32

Wolf management is a relatively new issue in Washington . During the initial phases of recovery 33

of the gray wolf under the Washington State E SA as outlined in the WCMPW

, federall y delisted 34

wolves involved in repeated depredation may be killed by WDFW

, WDFW authorized agents

, or 35

WS after confirmation by WDFW

. The requester will document unsuccessful attempts to solve 36

the situation through non

- lethal means

. WS may assist WDFW with determining the cause of 37

death in wolf damage complaints; however WDFW will make the final determination. WS may 38

also assist USFWS with the management of federally listed wolves in accordance with USFWS 39

guidance and/or the WMCPW . WS may also assist tribes with management of wolves on 40

sovereign tribal lands under the WCMPW or similar guidance. 41

42

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 3CHAPTER 1. PURPOSE AND NEED FOR ACTION

1.1 Purpose 1

2

Purpose of the Proposal 3

4

The purpose of th e proposed action is to reduce livestock depredation by gray wolves in 5

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

, 6

USFWS, sovereign tribal governments , or the public in the unlikely event that wolves threatened 7

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

. W S determi ned it would only 8

conduct actions on behalf of WDFW , USFWS, or tribal governments in accordance with 9

WDFW ’s conservation and management objectives and goal s as defined in detail in the 10

WCMPW or similar guidance

. 11

12

1.2 N eed for Action 13

14

Direct predation on livestock 15

16

The WCMPW calls for recovery of wolves in Washington , which provides a reason able 17

expectation that wolves in Washington will increase in number in the foreseeable future . Along 18

with the expectation of increased wolf numbers is the expectation that depredation on livestock 19

will also increase. The increasing presence of wolves in Washington initiated a need to mitigate 20

and resolve conflicts when wolves cause harm to lives tock. Lethal control of de

- listed wolves 21

may be necessary to resolve repeated wolf

- livestock conflicts and would be performed to remove 22

problem animals that jeopardize public tolerance for overall wolf recovery ( Wiles et al. 2011 ). 23

This EA discusses the di rect and indirect effects of wolf depredation on livestock and public 24

safety. 25

26

The first likely wolf depredation on livestock was reported in Stevens County in September 27

2007. More recent wolf attacks on livestock were confirmed July through September 201 2, in 28

northeastern WA. In August and September 2012, WDFW killed seven wolves from the Wedge 29

Pack, including the alpha male and female, in response to escalating wolf attacks on livestock 30

and “reset the stage for sustainable wolf recovery in this region” (WDFW Director Phil 31

Anderson, http://www.wdfw.wa.gov/news/sep2712b/). 32

33

The number of documented livestock killed by wolves to date in Washington may represent a 34

minimal numbe r, with more livestock kills probably going unconfirmed. Lethal control of 35

wolves may be necessary to resolve repeated wolf

- livestock conflicts and would be performed to 36

remove problem animals that jeopardize public toler ance for overall wolf recovery ( Wi les et al. 37

2011). Wolf control may also be conducted to protect public safety. WDFW requested WS to 38

assist so WDFW personnel could focus their efforts on conservation and recovery instead of 39

capture or removal. 40

41

Confirmed losses underestimate probable lo sses 42

43

It is important to recognize that the numbers of livestock that have been confirmed to be killed 44

by wolves to date in Washington may represent only the minimum numbers of livestock actually 45

killed and injured by wolves

, and that more livestock were probably killed but not confirmed as 46

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wolf predation ( Bjorge and Gunson 1985, Oakleaf et al. 2003). For example, in the Order 1

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

, one 2

Oregon ca ttle producer declared t hat he suffered the loss of two pregnant cows, one bull, and two 3

yearlings to wolves during part of a one year, but only two of his animals were confirmed as 4

wolf kills (Cascadia Wildlands, et al. v. Dept. of Fish and Wildlife, et a l. , No. 149672 (Or. Ct. 5

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

. For the 6

confirmed wolf kills, h e received a compensation payment in the amount of $800 4 but he 7

incurred additional losses of $6,600 . Thus, this producer was compensated for about 11 % of his 8

direct losses which totaled $7,400

. 9

10

Oakleaf et al. (2003) conducted a study on wolf

- caused predation losses to cattle on U.S. Forest 11

Service (USFS) summer grazing allotments near Salmon, Idaho, and concluded that for every 12

calf found and confirmed to have been killed by wolves, there were as many as 8 other calves 13

killed by wolves but not found by the producer , depending upon ruggedness or presence of 14

heavily timbered areas

. In areas less rugged or timbered, the ratio could be lower. Bjorge and 15

Gunson (1985) likewise recovered only 1 out of every 6.7 missing cattle during their study and 16

suggested that wolf

- caused mortalities were difficult to detect. 17

18

Confirmed incidents of wolf predation on livestock may involve only one or several livestock 19

killed or wounded per incident, but there have also been situations where larger numbers of 20

livestock have been killed in a single incident, particularly in the ca se of wolf attacks on sheep. 21

Muhly and Musiani (2009) reviewed data on wolf predation on livestock in Idaho, Montana and 22

Wyoming from 1987

- 2002 and found that while most wolf attacks on cattle involved the death of 23

only 1 animal per incident, wolf attacks on sheep typically involved killing about 14 animals per 24

incident, with up to 98 sheep killed in a single attack. In Oregon , one producer suffered 22 lamb 25

losses to wolves in one day. The same producer also incurred additional lamb losses and the loss 26

of a goat in the days and months that followed, all by the same wolves ( ODFW 2012). 27

28

WDFW require s a standard of conclusive evidence before wolf

- caused livestock depredations 29

are confirmed ( Wiles et al. 2011 ). In some cases, wolves may have been responsible for the 30

death of a rancher’s livestock, but there was insufficient evidence remaining to confirm wolf 31

predation. In other cases, those portions of the livestock carcass that might have contained the 32

evidence of pred ation may already have been consumed, carried off, or decomposed. Some of 33

these incidents might be classified as “probable” predation, depending on other evidence that 34

might still remain. But in many cases, there may be little or no conclusive evidence o f predation, 35

other than the fact that wolves are known to be in the area and some livestock have seemingly 36

disappeared. 37

38

As wolf populations increase and expand their range, local decision makers must choose 39

management strategies that balance competing nee ds for wolf protection and the reduction of 40

wolf

- caused damage (Mech 2001). Wolves prey on domestic animals in all parts of the world 41

where the two coexist (Mech and Boitani 2003, OWCMP 2010

, ). Data from the NRMDPS 42

suggest that individual wolves do not a utomatically prey on livestock, but members of wolf 43

4 Compensation was provided by a Defenders of Wildlife fund which is no longer in effect.

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packs encountering livestock on a regular basis are likely to depredate sporadically (Bangs and 1

Shivik 2001). 2

3

The relative risk of predation on livestock posed by individual wolves was analyzed by W S for 4

Idaho (USDA 2011 a ). The authors measured the likelihood for depredation to occur from 5

wolves, black bears, cougar s

, and coyotes and showed that individual wolves were more likely to 6

depredate on sheep and cattle than individual coyotes, bears

, and cougar s. 7

8

Where and how livestock are managed and where and how wolves are managed will influence 9

depredation rates. In Alberta, Canada, cattle on heavily forested but less intensively managed 10

grazing allotments suffered three times as many depredation incident s as more intensively 11

managed lease areas having less forest cover ( O DFW 2010)

. In North America and Europe, 12

untended livestock occupying remote pastures suffered the greatest losses from wolves. 13

Newborn livestock held in remote pastures are more vulnera ble to wolf predation. 14

15

Indirect depredation effects on livestock 16

17

Although direct losses of livestock due to predation are often conspicuous and economically 18

significant to affected producers , they likely underestimate the total impact on producers beca use 19

they do not consider indirect effects as a result of livestock being exposed to the threat of 20

predation (Howery and DeLiberto 2004, Lehmkuhler et al. 2007). Shelton (2004) suggested that 21

the value of livestock killed by predators is the “tip of the ic eberg” in assessing the actual costs 22

that predators impose on livestock and producers including time and effort spent looking for 23

missing livestock, and increased costs associated with efforts to mitigate predation which may 24

include night confinement, impr oved fencing, additional livestock guarding animals, early 25

weaning, choice of grazing area, and/or increased feeding costs related to loss of grazing 26

acreage. 27

28

Using an example of a producer in Oregon who incurred $ 7,400 in direct cattle losses (Cascadia 29

W ildlands, et al. v. Dept. of Fish and Wildlife, et al. , No. 149672 (Or. Ct. App. Nov. 15, 2011) 30

order staying enforcement of rule pending judicial review )

, increased labor and other costs 31

brought his economic impact from wolves during a portion of one year to over $18,000. Indirect 32

costs are not included in compensation payments, therefore, when considering his compensation 33

payment of $800 for a portion of his direct losses

, this producer was compensated for only about 34

four percent of his total (direct and indirect) losses. In a nother example (Cascadia Wildlands, et 35

al. v. Dept. of Fish and Wildlife, et al. , No. 149672 (Or. Ct. App. Nov. 15, 2011) order staying 36

enforcement of rule pending judicial review ) , a cattle producer which estimated $4,900 in cattle 37

l osses to wolf depredation, (not including lost profits), also incurred additional management 38

costs of $19,000. These examples illustrate the severity of indirect economic consequences that 39

wolf depredation and threats can have on individual livestock oper ations. 40

41

Indirect impacts to livestock arise from the stress and disruption associated with the presence of 42

wolves or wolves pursuing herd mates. Effects on livestock may include reduced weaning 43

weights, increased cattle aggressiveness, and delayed rebree ding, as well as increased production 44

cost s associated with an increased level of vigilance, alteration of pasture rotation and turnout 45

timing, and handling costs. Harassment by predators may directly cause livestock to lose weight 46

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due to increased energy expenditure associated with running and loss of sleep, but may also 1

indirectly reduce the ability of ruminants to convert plant nutrients into weight gain due to 2

decreased rumination time (Howery and DeLiberto 2004). Cattle and sheep exposed to 3

harassmen t by predators become very skittish and spend much of their time remaining vigilant 4

for predators (Kluever et al. 2008). They do not disperse and feed normally, and therefore may 5

not take in the quantity and quality of feed they would have if unstressed, resulting in reduced 6

weight gains at the end of the grazing season ( Muhly et al. 2010) . In addition, cattle are 7

sometimes stampeded through fences and injured when wolves chas e them (Lehmkuhler et al. 8

2007). Lehmkuhler et al. (2007) also suggested that w olves could stress cattle by chasing them 9

repeatedly which can also cause cattle to abort calves, cal ve early

, or give birth to a weak calf. 10

11

Wolf predation on dogs 12

13

As wolves expand their range in Washington , dog owners will need to be aware of the potent ial 14

risks to their animals. Areas or situations where wolves and domestic dogs encounter each other 15

can result in dog mortality. In some instances, wolves may alter their regular movements or 16

activities to seek out and confront domestic dogs ( O DFW 2010)

. In Wisconsin, wolf depredation 17

on hounds used for black bear hunting resulted in more compensation payments than for 18

livestock (Treves et al. 2002). In Minnesota, 25 dogs were reported killed by wolves in 1998 19

alone (Bangs and Shivik 2001, Mech and Boitani 2003). The killing of guard dogs by wolves 20

has been documented in the Rocky Mountain Recovery Area. However, g uard dogs appear to be 21

more effectiv e and less at risk when an adequate numbers of dogs per herd are present coupled 22

with the presence of trained herders. Livestock producers using working dogs in conjunction 23

with trained herders face added costs to protect their livestock from potential wo lf depredation. 24

Working dogs and trained herders may be more effective for protec ting sheep flocks than cattle 25

( O DFW 2010 )

. 26

27

In Washington , some wolves are likely to occupy areas near human habitation or areas used for 28

recreation which could put pets or w orking dogs at risk. Dogs working cattle or sheep could be 29

vulnerable in these situations. Public education will be important in preventing wolf/domestic 30

dog interactions. Livestock guarding and herding dogs are often highly valued animals, both 31

from a monetary standpoint and in terms of the human

- social bond. Individual livestock 32

guarding dogs may be worth more than $1,000 each. 33

34

To date, no working dogs have been confirmed as lost due to a wolf attack in Washington; 35

however, one dog guarding sheep in the vicinity of the Teanaway pack was injured, requiring 36

veterinary care (Dave Ware, WDFW, pers. comm.). A s wolf numbers increase, potential 37

conflicts could be expected

. 38

1.3 Scope of Analysis

– Location and Actions Analyzed 39

40

Location 41

42

Currently, federally delisted wolves occur within the Washington portion of the NR M DPS which 43

is defined as the area east of H ighway 97 from the British Columbia border south to Monse, 44

Highway 17 from Monse south to Mesa, and Highway 395 from Mesa south to the Oregon 45

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border

. Nonlethal w olf damage management may occur as requested by WDFW , USFWS, or 1

sovereign tribal governments wherever potential or confirmed repeated depredations arise

. 2

3

Wolf depredation management actions to assist WDFW , USFWS, or sov ereign tribal 4

gove rnments are currently expected to occur in very limited and isolated geographic locations 5

because wolves are not yet numerous or widely distributed in Washington , and thus resultant 6

conflicts have been relatively few, compared with confli cts in other states or by other predators 7

in Washington

. Even when wolf numbers increase, lethal removals would be limited t o th ose 8

constraints presented by WCMPW , USFWS regulations, or tribal autho rity

. 9

10

The likely location s included in the analysis would include any land at or near the depredation 11

incident

, and is likely t o occur on private

, state, tribal

, or federal land including U SFS and 12

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

. 13

14

If wolves are removed from the federal ESA outside the NRMDPS , they would be managed by 15

WDFW under the WCMPW

. Thus any actions allowed by the WCMPW , as amended

, would 16

apply to wolves throughout the state

. While no packs have become established in the Southern 17

Cascades and Northwest Coast , expansi on into the western third of Washington is anticipated

. 18

19

Site Specificity 20

21

This EA analyzes the potential impacts of WS’ wolf damage management on all lands in 22

Washington where conflicts with livestock and human safety may occur. Specific locations or 23

times where such damage will occur cannot be predicted due to the mobil ity and unpredictability 24

of wolves, and the distribution of livestock across the Washington landscape. Ther e fore, t his EA 25

anticipates all substantive environmental issues that are likely to exist where wolf dam a ge 26

management may occur . The WS Decision Model (Slate et al. 1992) is the s ite

- specific 27

mechanism for determining the most appropriate actions to take within the scope of actions 28

allowed under any NEPA decision. Any sub stantive new issue or change in circumstance that 29

might arise with wolf damage management which has not been considered in this EA may 30

require additional NEPA compliance. Therefore this EA meets the intent of NEPA with regard 31

to site

- specific analysis

. 32

33

A ctions Analyzed 34

35

This EA evaluates WS proposed actions to assist WDFW , USFWS, or tribal governments in 36

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

- lethal 37

methods that can be used to aid in wolf conflict prevention, and to lethally remove federally 38

delisted wolves at the request of WDFW or tribes if wolves have been confirmed as having 39

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

. WS also 40

proposes to assist WDFW , USFWS, and sovereign tribal governments by using its expertise to 41

determine whether or not wolves were responsible for depredation. Other than on sovereign 42

tribal lands, only WDFW or USFWS will make the final confirmation of repeated livestock 43

depredation. L eth al take of federally delisted wolves under WDFW control is allowed by 44

livestock owners, (including family members and authorized employees) on private land they 45

own or lease at all listed statuses, with an issued permit, after documented depredation (injur y or 46

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killin g) in the area and efforts to resolve the problem have been deemed ineffective (WDFW 1

2011 ). On 26 April 2013, WDFW enacted an emergency rule: 2

3

WAC 232

- 36

- 05100B Killing wildlife causing private property damage 4

Notwithstanding the provisions of WAC 232

- 36

- 051: 5

6

1) An owner of domestic animals, including livestock, the owner's immediate 7

family member, the agent of an owner, or the owner's documented employee may 8

kill one gray wolf (Canis lupus) without a permit issued by the director, regardless 9

of its state classification, if the wolf is attacking their domestic animals. 10

(a) This section applies to the area of the state where the gray wolf is not listed 11

as endangered or threatened under the federal endangered species act. 12

(b) Any wolf killed under this authority must be reported to the department 13

within twenty

- four hours. 14

(c) The wolf carcass must be surrendered to the department. 15

(d) The owner of the domestic animal must grant or assist the department in 16

gaining access to the property whe re the wolf was killed for the purposes of data 17

collection or incident investigation. 18

19

(2) If the department finds that a private citizen killed a gray wolf that was not 20

attacking a domestic animal, or that the killing was not consistent with this rule, 21

th en that person may be prosecuted for unlawful taking of endangered wildlife 22

under RCW 77.15.120. 23

24

(3) In addition to the provisions of (1), the director may authorize additional 25

removals under RCW 77.12.240. 26

27

WS may act as an authorized agent on a depredat ion permit, to remove federally delisted gray 28

wolves under WDFW permit conditions for livestock producers or permittees. The specific non

29

lethal and lethal measures to reduce wolf conflicts are discussed in detail in the Sections 2. 1 and 30

2.3. At the requ est of USFWS or WDFW acting as an authorized agent of USFWS, WS may 31

take nonlethal actions towards federally listed wolves. WS would not take any actions towards 32

federally listed wolves outside the guidance of the ESA. On tribal lands, WS may assist trib al 33

governments with all forms of wolf management. All assistance provided by WS would comply 34

with the WCMPW or similar guidance. 35

36

A critical factor guiding this analysis is that WS wolf damage management activities wou ld be 37

conducted only at the request of WDFW

, USFWS, affected property owners (for nonlethal 38

assistance)

, and tribal governments. WS has no decision making authority for where or when to 39

remove problem wolves when acting at the request of USFWS, WDFW or WDFW au thorized 40

depredation permit holders

. WS can only decide if it will accept WDFW , USFWS, or tribal 41

request s to remove problem wolves. Wolf damage management strategies are established in the 42

WCMPW to ensure conservation and management goals will be met, th erefore, any action 43

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

. As discussed 44

under the proposed action, on tribal lands WS would conform to similar implementation 45

guidelines for the management of wolf depredation including limitations on the lethal removal of 46

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wolves . Where wolves are federally listed, WS would not take any lethal actions outside the 1

guidance of the ESA

. 2

3

WDFW will remove problem wolves in the absence of assistance from WS ( Appendix A ). 4

R equests for assistance by s overeign tribal governme nt s in the foreseeable future are p ossible but 5

not likely . Therefore the actions analyzed in this EA are weighed against the environmental 6

baseline or the environmental status quo of wolf depredation management by the responsible 7

wildlife management agencies. 8

9

1. 4 WDFW Wolf Management Goals 10

11

Under WDFW request, WS actions would abide by the WCMPW

. A ny work performed by WS 12

on tribal lands or where wolves are federally listed, would conform to tribal /federal regulations 13

or similar implementation guidelines outlined in the WCMPW

. 14

15

Managing livestock conflicts : WDFW ’s objectives for addressing wolf damage to livestock , as 16

stated in the WCMPW

, are to develop and implement a phased approach based on population 17

objectives for wolves that ensures conservation of the species while minimizing conflicts with 18

livestock

. 19

20

Managing wolf populations : WDFW ’s wol f population objectives are separated into three 21

regions : Eastern Washington, Northern Cascades, and Southern Cascades and Northwest Coast 22

(Figure 2). The Northern Cascades zone and Southern Cascades and Northwest Coast zone fall 23

outside the NRMDPS and are currently under federal ESA rules. 24

25

The goals of the WCMPW are to: 26

27

• Restore the wolf population in Washington to a self

- sustaining size and geographic 28

distribution that will result in wolves having a high probability of persisting in the state 29

throug h the foreseeable future (>50

- 100 years). 30

• Manage wolf

- livestock conflicts in a way that minimizes livestock losses, while at the 31

same time not negatively impacting the recovery or long

- term perpetuation of a 32

sustainable wolf population. 33

• Maintain healthy and robust ungulate populations in the state that provide abundant prey 34

for wolves and other predators as well as ample harvest opportunities for hunters. 35

• Develop public understanding of the conservation and management needs of wolves in 36

Washington, thereb y promoting the public’s coexistence with the species. 37

38

Meeting the delisting criteria outlined in WCMPW will necessitate tolerance for wolves on 39

public and private lands. Therefore, to achieve conservation of wolves in Washington as 40

required by the state ESA, the WCMPW outlines a range of options for livestock producers to 41

deal with problem wolves. While the WCMPW describes measures that WDFW will take to 42

conserve and manage the species, it provides for non

- lethal and lethal management strategies that 43

co uld be taken to protect livestock from wolf depredation and address human safety concerns. 44

These measures are outlined in Section 2.3 and detailed in the WCMPW

. 45

46

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1.5 Period for which this EA Remains Valid 1

2

This EA may remain valid until W S , in consultation with WDFW , USFWS, and affected 3

sovereign trib al government s , determines that the need for action, issues driving this EA, 4

environmental conditions, or wolf management plans have change d substantially

. Substantive 5

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

, further involve the 6

public , and provide the decision

- maker with additional information necessary to make an 7

informed decision about WS ’ role in wolf damage management in Washington

. The need f or 8

action to protect livestock from wolf predation and protect public safety

, as described i n Section 9

1.2

, woul d be expected to increase over time as Washington ’s wolf populations grow and 10

expand

. The WCMPW use s a daptive management to incorporate new information into 11

WDFW ’ s management schemes which may affect when and where W S would take actions. WS 12

would follow this adaptive management scheme by adjusting to the changes. Wolf management 13

as conducted by WDFW is e xpected to continue into the for e seeable future and result in an 14

eventual State delisting

. 15

16

1.6 Decision to be Made 17

18

Based on agency relationships, Memoranda of Understand ing ( MOUs ) and legislative direction, 19

WS is the lead a gency for this EA, and therefore responsible for the scope, content

, and decisions 20

made

. WDFW and USFWS were consulted during the development of the EA, and the USFS, 21

BLM, Washington Department of Agriculture ( W DA), and tribes had opportunity for input 22

during preparation of the EA

. 23

24

Based on the scope of this EA, the decisions to be made are: 25

• Should the Washington WS program respond to WDFW requests for assistance with the 26

WCMPW as well as assisting USFWS and sovereign tribal g overnments ? 27

• Might there be other reasonable alternatives that could be selected? 28

• What are the likely environmental effects o f the alternatives, and could the proposed 29

action have significant effects on the quality of the human environment and therefore 30

req uire an EIS? 31

32

1.7 Summary of Public Involvement Efforts 33

34

Scoping, agency, and p ublic input in the NEPA process for this EA were conducted consistent 35

with W S NEPA procedures . Issues related to the proposed action were identified from : 36

cooperating agency input from WDFW including the WCMPW and Final EIS for Wolf 37

Conservation and Management Plan for Washington, prior WS experience with wolf 38

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

, agency 39

knowledge of wolf damage management issues in Washington , and interagency and tribal 40

reviews of the draft EA

. 41

42

This EA was made available to the public b y posting the notice of its availability on the W S 43

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

, b y issuing a legal notice in 44

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

- decision al EA on 45

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 11CHAPTER 1. PURPOSE AND NEED FOR ACTION

http://www.regulations.gov/#!docketDetail;D=APHIS

- 2013

- 0107

. All substantive comments 1

received according to the instruction s provided in the notices will be considered in the finalized 2

EA. A summary of public comments and response will be contained in Appendix C after they 3

are received

. 4

5

1.8 Rela tionship of this E A to other Environmental Documents 6

7

Final Rule to Delist NRMDPS 8

9

On 5 May 2011, USFWS published a final rule to remove protections of the E SA from most of 10

the concurrently designated gray wolf NRMDPS (74 FR 15123) . The population of wolves in 11

the eastern one third of Washington was included in this delisting, as they were part of the 12

NRMDPS. B ackground information on the NRM gray wolf population was contained in the 13

USFWS 2 April 2009, F inal R ule (74 FR 15123) http://www.regulations.gov 5 14

15

201 1 Wolf Conservation and Management Plan for Washington. 16

17

The WCMPW provides relevant discussions which are summarized herein. The relationship of 18

the WCMPW to th is EA is that it provides the framework and basis for describing the existing 19

environment and no action alternative, and it sets parameters and limitations on the proposed 20

action. Th e No Action and Eliminate the Current Wolf Assistance Program alternatives are not 21

consistent with WDFW management goals and objectives, as specified in the WCMPW

. 22

23

Final Environmental Impact Statement for the Wolf Conservation and Management Plan for 24

Washington. 25

26

WDFW issued a Final EIS on wolf c onservation and management for Washington on 28 July 27

2011. This document se rved as a backbone for the WCMPW and relevant information available 28

in the EIS has been incorporated by reference into this EA. 29

30

Wildlife Services Programmatic Final E nvironmental I mpact S tatement 31

32

W S issued a Final E IS on the national APHIS

- W S program and Record of Decision published in 33

1995. The FEIS received minor updates in 1997 (USDA 199 7 ). Relevant information available 34

in the EIS has been incorporated by reference into this EA. 35

36

37

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.

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Final EIS on the Reintroduction of Gray Wolves to Yellowstone National Park and Central Idaho 1

2

The USFWS (1994) issued a Final EIS and Decision regarding the potential impacts of 3

reintroducing wolves to YNP and c entral Idaho. Part of the analysis in the EIS assessed potential 4

impacts of a fully

- recovered wolf population on livestock

. This EIS also assessed the anticipated 5

impact of wolf removals for protection of livestock. Relevant analysis from USFWS (1994) is 6

incorporated by reference in this EA. 7

8

1. 9 Authority and Compliance 9

10

W S cooperates with land and wildlife management agencies to resolve wildlife damage pro blems 11

in compliance with applicable federal

, s tate and local laws. 12

13

1.9.1 Authority of Federal and State Agencies in Wolf Damage Management 14

15

APHIS

- Wildlife Services 16

17

The W S program is authorized to carry out wildlife damage management programs necessary to 18

protect the Nation’s agricultural and other resources. The primary statutory authorities are the 19

Act of March 2, 1931 (46 Stat . 1468; 7 U.S.C. 426

- 426b ) as amended, and the Act of December 20

22, 1987 (101 Stat. 1329

- 331, 7 U.S.C. 426c). WS recognizes that wildlife is an important 21

public resource greatly valued by the American people. By its very nature, however, wildlife is a 22

hig hly dynamic and mobile resource that can damage agricultural resources, pose risks to human 23

safety, and affect other natural resources. The WS program provides federal leadership in 24

helping to solve problems that occur when human activity and wildlife are in conflict with one 25

another. 26

27

United States Bureau of Land Management (BLM) 28

29

The BLM manages lands under its jurisdiction for multiple uses including livestock grazing, 30

recreation, wildlife habitat, and other uses while recognizing the state's authority to manage 31

resident wildlife. The BLM recognizes the importance of managing wildlife damage on lands 32

and resourc es under its jurisdiction, as integrated with its multiple use responsibilities. Similar to 33

the USFS, BLM and W S have entered into a MOU which identifies the roles and responsibilities 34

of each agency in animal damage management operations

, coordination, and NEPA compliance. 35

WS currently does not conduct work on BLM lands , but may so at their request or may 36

coordinate with them when requested by a grazing leasee. 37

38

United States Fish and Wildlife Service (USFWS) 39

40

The USFWS is a federal agency within the U.S. Department of the Interior authorized to manage 41

fish, wildlife, and habitats. USFWS mission reads, “working with others to conserve, protect, 42

a nd enhance fish, wildlife, plants and their habitats for the continuing benefit of the American 43

people.” As the principal federal agency responsible for administering the ESA, the USFWS 44

takes the lead in recovering and conserving imperiled species by foste ring partnerships, 45

employing scientific excellence, and developing a workforce of conservation leaders. 46

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U nited States Forest Service (USFS) 1

2

The USFS has the responsibility to manage National Forests for multiple uses including 3

livestock grazing, timber production, recreation, and wildlife habitat, while recognizing the 4

state's authority to manage r esident wildlife. The USFS r ecognize s the importance of managing 5

wildlife damage on lands and resources under their jurisdiction , as integrated with their multiple 6

use responsibilities. The USFS and WS have a MOU agreeing that “APHIS

- WS is designated as 7

the lead agency concerning wildlife damage management ( WDM ) and wildlife disease activities, 8

and that in evaluating the need for, and in conducting WDM programs, multiple

- use values must 9

be considered ”. The MOU directs the USFS to coordinate with W S in the development and 10

annual review of wildlife damage management plans governing W S ’ activities on National 11

Forest System lands and to cooperate in W S ’ NEPA processes. WS currently does not work on 12

USFS lands, but could be requested to do so in the future. Work done on USFS lands would be 13

conducted in coordination with the Regional Forester and under annual WD M work plans. In 14

this way, the USFS ensure s that proposed wildlife damage management activities are consistent 15

with forest land uses as allowed under its Land and Resource Management Plans and Forest 16

Plans. 17

18

Washington Department of Fish and Wildlife 19

20

WDF W has the authority to manage all wildlife in Washington. RCW 77.04.012 mandates that 21

“t he commission, director, and the department [WDFW] shall preserve, protect, perpetuate, and 22

manage the wildlife and food fish, game fish, and shellfish in state waters and offshore waters ”. 23

In part, this policy states that the WDFW shall conserve the wildlife and food fish, game fish, 24

and shellfish resources in a manner that does not impair the resource and may authorize the 25

taking of wildlife, food fish, game fish, and shellfish only at times or places, or in manners or 26

quantities, as in the judgment of the commission does not impair the supply of these resources. 27

28

1. 9 .2 Compliance with Federal and State L aws , Policies and Executive Orders 29

30

Several f ederal and s tate laws regulate wildlife damage management. W S complies with 31

relevant federal and s tate laws, and consult s and cooperate s with other agencies as appropriate. 32

33

Bureau of Land Management 34

35

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

- 426c), BLM and W S , along with the states, 36

cooperate to manage animal damage on B LM lands. Similar to the USFS, BLM and W S have 37

entered into a MOU which identifies the roles and responsibilities of each agency in animal 38

damage management operations and coordination, and NEPA compliance. The BLM is 39

responsible for the mana gement of land and resources under its jurisdiction and for conducting 40

non

- predator control operations on its’ lands, including NEPA compliance on these activities. 41

The MOU directs BLM to coordinate with W S in the development and annual review of animal 42

d amage management work plans governing W S ’ activities on BLM lands and to cooperate in 43

W S NEPA processes. 44

45

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- Wildlife Services’ Gray Wolf Damage Management In Washington 14CHAPTER 1. PURPOSE AND NEED FOR ACTION

Executive Order (EO) 12898

- Federal Actions to Address Environmental Justice in Minority 1

Populations and Low

- Income Populations 2

3

Environmental Justic e (EJ) promotes the fair treatment of people of all races, income and culture 4

with respect to the development, implementation and enforcement of environmental laws, 5

regulations and policies. Fair treatment implies that no person or group of people should endure 6

a disproportionate share of the negative environmental impacts resulting either directly or 7

indirectly from the activities conducted to execute this country's domestic and foreign policies or 8

programs. All WS activities are evaluated for their impa ct on the human environment and 9

compliance with EO 12898 to ensure EJ. WS personnel use wildlife damage management 10

methods as selectively and environmentally conscientiously as possible. No pesticides are 11

proposed for use. It is not anticipated that the proposed action would result in any adverse or 12

disproportionate environmental impacts to minority or low

- income persons or populations. 13

14

EO 13045

- Protection of Children from Environmental Health and Safety Risks 15

16

Children may suffer disproportionately from environmental health and safety risks for many 17

reasons. Wolf damage management as proposed in this EA would only involve legally available 18

and approved damage management methods in isolated or remote situations and otherwise under 19

circumstances where it is highly unlikely that children would have an opportunity to be exposed 20

and potentially be adversely affected. Therefore, implementation of the proposed action would 21

not increase environmental health or safety risks to children. 22

23

Federal Endangered S pecies Act 24

25

It is federal policy, under the ESA, that all federal agencies shall seek to conserve endangered 26

and threatened species and shall utilize their authorities in furthera nce of the purposes of the 27

ESA [ Sec. 7(a)( 2 )] . Section 7 consultations with the USFWS are conducted to use the expertise 28

of the USFWS to ensure that "any action authorized, funded, or carried out by such an agency is 29

not likely to jeopardize the continued existence of any endangered or threatened species. W S 30

conducts Section 7 Co nsultations with the US FWS when proposed actions may affect federally 31

listed species. 32

33

Under Section 11(a)(3), “Notwithstanding any other provision of this Act, no civil penalty shall 34

be imposed if it can be shown by a preponderance of the evidence that the defendant committed 35

an act based on a good faith belief that he was acting to protect himself or herself, a member of 36

his or her family, or any other individual from bodily harm, from any endangered or threatened 37

species.” 38

39

Fish and Wildlife Act of 1956 (section 742j

- 1) Airborne Hunting 40

41

This Act, approved in 1971

, was added to the Fish and Wildlife Act of 1956 and is commonly 42

referred to as the Airborne Hunting Act or Shooting from Aircraft Act. The Act allows shooting 43

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

, and human 44

life as authorized by a federal or state issued license or permit. USFWS regulates the Airborne 45

Hunting Act but has given implementation to the state s

. WDFW or its agent is authorized to 46

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- Wildlife Services’ Gray Wolf Damage Management In Washington 15CHAPTER 1. PURPOSE AND NEED FOR ACTION

conduct aerial shooting as described under this proposal according to WAC 232

- 12

- 057 (Hunting 1

with the aid of airc raft, boats, or other vehicles). 2

3

N ational E nvironmental P olicy A ct 4

5

NEPA requires that federal actions be evaluated for environmental impacts, that these impacts be 6

considered by the decision maker(s) prior to implementation, and that the public be informed. 7

This EA has been prepared in compliance with NEPA (42 USC Section 4231, et seq.,); the 8

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

– 9

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

. 10

11

O ne purpose of any EA is to “. . . briefly provide sufficient evidence and analysis for 12

determining w hether to prepare an environmental impact statement or a finding of no significant 13

impact” (40 CFR 1508.9). If the environmental impacts are found to be significant, the NEPA 14

process would likely be continued and an E IS would be prepared. If the impacts of the proposal 15

are not found to be significant on the human environment, a Finding of No Significant Impact 16

and decision to implement a selected alternative may be issued. 17

18

National Historic Preservation Act (NHPA) of 1966, as amended 19

20

The NHPA requires federal agencies to: 1) evaluate the effects of any federal undertaking on 21

cultural resources, 2) consult with the State Historic Preservation Office regarding the value and 22

management of specific cultural, archaeological and historic resources, and 3) con sult with 23

appropriate American Indian tribes to determine whether they have concerns for traditional 24

cultural resources in areas of these federal undertakings. We have determined that the proposed 25

action is not a federal “undertaking” as defined by NHPA a nd would not affect cultural 26

resources. 27

28

Tribal Authorities 29

30

When working with Tribes, the Departments recognize that Indian lands, whether held in trust by 31

the United States for the use and benefit of Indians or owned exclusively by an Indian tribe, are 32

n ot subject to the controls or restrictions set forth in federal public land laws. Indian lands are not 33

federal public lands or part of the public domain, but are rather retained by tribes or set aside for 34

tribal use pursuant to treaties, statutes, court or ders, executive orders, judicial decisions, or 35

agreements. Accordingly, Indian tribes manage Indian lands in accordance with tribal goals and 36

objectives, within the framework of applicable laws

. 37

38

U.S. Fish and Wildlife Service 39

40

Currently wolves in the NRM are managed by the USFWS with cooperation from the other 41

agencies and tribes. While all federal agencies have the responsibility to “utilize their authorities 42

in furtherance of the purposes of the ESA . . . pursuant to section 4” of the ESA, the USFWS has 43

primary authority for endangered species recovery. Currently, the USFWS has legal 44

responsibilities for wolf recovery in the western 2/3 rd of WA; however, the USFWS can, through 45

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- Wildlife Services’ Gray Wolf Damage Management In Washington 16CHAPTER 1. PURPOSE AND NEED FOR ACTION

cooperative agreements and other documents permit the states and tribes to lead implementation 1

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

. 2

3

Fish and Wildlife Service regulations authorize certain federal and state employees and agents 4

(which could include WS) , when acting within the s cope of their official duties, to take 5

endangered and threatened species without a permit, "to aid a sick, injured, or orphaned 6

specimen," to "dispose of a dead specimen," to "[s]alvage a dead specimen which may be useful 7

for scientific study," or to "remo ve specimens which pose a demonstrable but nonimmediate 8

threat to human safety." 50 C.F.R. §§ 17.21(c)(3), .21(c)(4), .31(a) (1993). 9

10

U.S. Forest Service 11

12

Under the Act of 1932, as amended, (7 U.S.C. 426

- 426c), the USFS and W S , along with the 13

states, coope rate to manage animal damage on National Forest System lands. Under the 14

framework of a 2011 MOU between the USFS and W S (Appendix B) , W S is designated as the 15

lead agency concerning animal damage management activities involving predators on National 16

Forest System lands. This includes a responsibility to maintain technical expertise in the science 17

of animal damage management, control tools and techniques, conducting management programs, 18

and complying with the NEPA for activities related to predator damage m anagement. 19

20

The USFS is responsible for the management of land and resources under its jurisdiction. The 21

MOU directs the USFS to coordinate with W S in the development and annual review of wildlife 22

damage management plans governing W S ’ activities on Nation al Forest System lands and to 23

cooperate in W S ’ NEPA processes. WS currently does not work on USFS lands, but could be 24

requested to do so in the future. Work done on USFS lands would be conducted in coordination 25

with the Regional Forester and under annual WDM work plans. 26

27

Washington Endangered Species Act 28

29

The Washington E SA ( WAC 232

- 12

- 297 ) provides protection for any wildlife species native to 30

the state of Washington that is seriously threatened with extinction throughout all or a significant 31

portion of its range within the state an d any wildlife species native to the state of Washington 32

that is likely to become an endangered species within the foreseeable future throughout a 33

significant portion of its range within the state without cooperative managem ent or removal of 34

threats

. 35

36

WDFW

- Mandate ( RCW 77.04.012 ) 37

38

RCW 77.04.012 mandates that “t he commission, director, and the department [WDFW] shall 39

preserve, protect, perpetuate, and manage the wildlife and food fish, game fish, and shellfish in 40

state waters and offshore waters ”. In part, this policy states that the WDFW shall conserve the 41

wildlife and food fish, game fish, and shellfish resources in a manner that does not impair the 42

resource and may authorize the taking of wildlife, food fish, game fi sh, and shellfish only at 43

times or places, or in manners or quantities, as in the judgment of the commission does not 44

impair the supply of these resources. 45

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- Wildlife Services’ Gray Wolf Damage Management In Washington 17CHAPTER 2. DESCRIPTION OF ALTERNATIVES



### CHAPTER 2. DESCRIPTION OF ALTERNATIVES 1

2

WDFW requested Wildlife Services (WS) to assist them with managing wolves and wolf 3

damage. Without WS assistance, w olf damage management will be implemented by WDFW 4

according to the WCMP W ( Appendix A ). WS developed three reasonable alternatives in 5

response to the request assist with wolf damage management in WA

. The Current Program “ N o 6

A ction” alternative was evaluated for comparison to describe the environment al baseline. “No 7

Action” means no change from the status quo. The statu s quo is that WS provides technical 8

assistance and some non

- lethal control methods to people in Washington asking for help. If WS 9

selected the Current Program “No Action” alternative, WDFW would implement the WCMPW 10

to the best of its ability, including le thal control of wolv es ( Appendix A ). T he second alternative 11

is the Eliminate the Current Wolf Assistance Program alternative. This would prevent WS from: 12

1) conducting any wolf damage management, 2) providing any technical assistance, and 3) 13

assisting in public education and outreach of wolf issues. The Proposed alternative, Expand the 14

Current Wolf Assistance Program alternative, would allow WS to develop an integrated 15

approach to respond to requests from WDFW , USFWS, and tribes to assist with several as pects 16

of the WCMPW or similar guidance , including lethally removing wolves to enhance overall 17

conservation and recovery efforts. 18

19

Within the limited decision space afforded WS by the WCMPW , WS has no regulatory authority 20

or latitude to implement other appr oaches, nor can it require alternative actions /requests of 21

WDFW , USFWS, or tribes

. 22

23

2.1 Alternative 1

- No Action 24

25

The Current Program “No Action” Alternative is for WS to continue its existing wolf damage 26

management actions, as is. This is the environmental status quo

, a required NEPA component , a 27

viable alternative that could be selected, and serve s as a baseline for comparing the action 28

alternatives (CFR 1502.14[d]). Under this alternative, WS would continue its current activities 29

conducting investigations of livestock conflicts, providing the public with advice and 30

recommendations on the appropriate use of non

- lethal methods to protect livestock from wolf 31

damage, and performing select non

- lethal control actions to reduce wolf damage. 32

33

Wildl ife Services assists and reports to WDFW and USFWS (in areas where wolves are federally 34

listed) in conducting livestock damage investigations. When mortality events are determined to 35

be caused by predation, they are investigated further to determine the s pecies that caused the 36

damage. If wolves may be potentially involved, WS coordinates investigation activities with 37

WDFW /USFWS and/ or other appropriate agencies. 38

39

Non

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

- activated guard 40

(R AG) devices, non

- injurious harassment, non

- lethal injurious harassment, fladry, range riders

, 41

animal husbandry practices, installation of fencing, and the use of livestock guarding animals. 42

43

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- Wildlife Services’ Gray Wolf Damage Management In Washington 18CHAPTER 2. DESCRIPTION OF ALTERNATIVES

WS provide s the results of confirmed, probable, and possible wolf conflict investigations to 1

WDFW /USFWS , but would not provide lethal rem oval assistance to WDFW, USFWS, tribes, or 2

livestock producers to alleviate confirmed wolf damages. WDFW stated that they would co nduct 3

the necessary actions as described in the WCMPW to remove repeated depredating wolves if the 4

WS program were not available (Appendices A). Therefore, the Current Program “No Action” 5

alternative must be evaluated as the conditions u nder which gray wo lves are managed by 6

WDFW

. 7

8

The WCMPW describe s measures the WDFW w ould take to conserve and manage wolves, 9

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

. The following 10

summarizes the primary components of the WCMPW, but removes WS from conduct ing lethal 11

removal or trapping of wolves for WDFW /USFWS under th is “no action” alternative. 12

13

Under this alternative (No Action), WS would not conduct any trapping or lethal control. 14

However, the following actions may still occur by o ther agencies and/or individuals : 15

16

• In areas where wolves are federally delisted but listed as a state endangered species under 17

WAC 232

- 12

- 297

, the WCMPW allow s for the following actions, which may be 18

implemented by WDFW or its agents , USFWS, tribes, and WS (except for live trapping, 19

relocation, and lethal removal) : 20

o Non

- injurious harassment: Livestock owners and grazing allotment holders (or their 21

designated agents) will be allowed to harass wolves with non

- injurious techniques when 22

wolves are in close proxi mity to livestock or livestock grazing areas on private and public 23

land. These techniques could include scaring off an animal(s) by firing shots or cracker shells 24

into the air, making loud noises, or other methods of confronting the animal(s) without doing 25

bodily harm. 26

o Non

- lethal injurious harassment: This form of harassment involves striking wolves with non

27

lethal projectiles, such as rubber bullets specifically designed and approved for use on 28

wolves, paintballs, and beanbags (Bangs et al. 2006). Livestock owners and grazing allotment 29

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

- lethal injurious 30

harassment on their own land or their legally designated allotment, respectively. WS would 31

not apply injurious harassment toward wolves under this alternative

. 32

o Relocate individual wolves: Relocating an individual wolf is a possible management tool to 33

remove the animal from a conflict situation. This activity would be evaluated on a case

34

specific basis, but would especially be consid ered during endangered and threatened status. 35

WS would not capture or relocate wolves under this alternative

. 36

o Any relocation would be conducted by WDFW, or its agents, in co nsultation with the 37

appropriate land management agency and the USFWS , if wolves ar e federally listed in that 38

portion of the state. 39

o Lethal control to resolve repeated livestock depredations: WS would not conduct lethal 40

removal under this alternative; however, l ethal removal may be used by others to stop 41

repeated depredation if it is docu mented that livestock have been killed by wolves, non

- lethal 42

methods have been tried but failed to resolve the conflict, depredations are likely to continue, 43

and there is no evidence of intentional feeding or unnatural attraction of wolves by the 44

livestock owner. In areas of Washington where wolves are federally listed, any proposal to 45

lethally control wolves would have to be consistent with federal law. WDFW does not have 46

authority to lethally remove wolves where they are feder ally listed. During state en dangered 47

and threatened status, lethal control would be conducted by WDFW or its agents. If a 48

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- Wildlife Services’ Gray Wolf Damage Management In Washington 19CHAPTER 2. DESCRIPTION OF ALTERNATIVES

situation were to occur where WDFW did not have the reso urces to address a situation of 1

repeated depredations, WDFW may consider issuing a permit to a livestock o wner to conduct 2

lethal control during a specific time period on private lands they own or lease. 3

o Lethal take in the act of attacking livestock: WS would not lethally remove wolves under this 4

alternative. This provision allows lethal take of federally delisted wolves “in the act” of 5

attacking livestock (defined as biting, wounding, or killing; not just chasing or pursuing) by 6

livestock owners, family members, and authorized employees with an issued WDFW permit 7

on private land they own or lease (including federal grazing allotments) during all state listed 8

statuses. This provision would not be available in areas of the state where wolves are 9

federally endangered. Federal law does not allow lethal take of an endangered species in the 10

act of attac king livestock. At federal threatened status, there is more management flexibility 11

through federal regulations. Wherever wolves are federally listed in Washington, the U.S. 12

Fish and Wildlife Service is the lead management authority. In these areas, WDFW wi ll 13

consult with and collaborate with the U.S. Fish and Wildlife Service on management 14

decisions and actions to ensure consistency with federal law. State law (RCW 77.15.120) 15

prohibits the killing of an endangered species unless it has been authorized by r ule of the 16

commission. Subject to limitations established by the commission, certain private citizens 17

may kill wildlife that is threatening human safety or causing property damage. Under RCW 18

77.36.030, the conditions set by the commission must include “app ropriate protection for 19

threatened or endangered species.” It also states that in establishing the limitations and 20

conditions related to wolves, the commission “shall take into consideration the 21

recommendations of the Washington state wolf conservation and management plan.” Under 22

WAC 232

- 36

- 051, it is unlawful to kill state endangered species causing damage to 23

commercial livestock unless authorized by commission rule or WDFW permit. 24

25

• The federal Endangered Species Act provides that “...any person may take e ndangered wildlife in 26

defense of his own life or the lives of others” (50 CFR 17.21(c)(2)). State law also makes it 27

permissible to kill “...wild animals engaged in the physical act of attacking a person” (Chapter 28

WAC 232

- 36

- 050(3)(a)). It is important to un derstand that wolves passing near, watching, or 29

otherwise behaving in a non

- threatening way near humans should not necessarily be considered 30

as dangerous. Under these circumstances, wolves could and should be hazed using non

- lethal 31

methods; use of lethal force is unneeded and illegal. 32

33

• A strong information and education program is proposed to ensure anyone with an interest in 34

wolves is able to learn more about the species and stay informed about wildlife management 35

activities. 36

37

• Several research projects are identified as necessary for future success of long

- term wolf 38

conservation and management. Monitoring and radio

- collaring wolves are listed as critical 39

components of the WCMPW for conservation and communication with Washingtonians. 40

41

Based on experience s in other states, wolf depredation on livestock is expected to occur in 42

Washington as wolves become reestablished. Resolving wolf

- livestock conflicts will require 43

non

- lethal and lethal control responses. Resolution of conflicts will need to be managed in a way 44

that does not jeopardize recovery of the species and is consistent with state and federal laws

. 45

This approach for managing a listed species is highly unusual, but is required because of the 46

desire to reduce conflicts and build social tolerance for wo lves, thereby enhancing the chances 47

for reestablishing the species in the state. 48

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The WCMPW endeavors to provide as much flexibility to address conflicts as possible while still 1

remaining focused on achieving wolf conservation goals. This incremental appro ach is designed 2

to provide options to wolf managers, livestock producers, and the public while promoting the 3

goal of conservation for wolves. The WCMPW provides that WDFW can authorize the killing of 4

federally delisted wolves due to repeated livestock loss es when the requester has documented 5

unsuccessful attempts to solve wolf

- livestock conflict with non

- lethal methods. 6

7

Management approaches are based on the status of wolves, ensuring that recovery objectives are met. 8

Non

- lethal management techniques will be emphasized throughout the recovery period and beyond. 9

Actively informing and equipping landowners, livestock produc ers, and the public with tools to 10

implement proactive wolf damage management techniques will be an important aspect of this 11

approach. Lethal control will be used only as needed after case

- specific evaluations are made, with 12

use becoming less restrictive as wolves progress toward delisting. WS would not conduct lethal 13

removal under this alternative. 14

15

Currently, state laws RCW 77.36 and WAC 232

- 36 allow owners of commercial livestock (cattle, 16

sheep, and horses held or raised by a person for sale) to be compe nsated by WDFW for animals 17

killed or injured by bears, cougars, and wolves if required conditions are met. This plan provides for 18

a state compensation program for documented confirmed and probable wolf

- killed livestock in order 19

to reduce the financial los ses that some livestock producers might experience while wolves are state 20

listed. Public support for a state

- funded wolf compensation program was expressed in the comments 21

received during public meetings in 2007 and 2009 and the plan’s public review period in 2009

- 2010. 22

An effective compensation program supported by the public and Legislature can also help maintain 23

tolerance for wolves among some landowners and livestock producers (Bangs et al. 2006, Stone 24

2009), which can help decrease illegal killings an d aid wolf recovery. 25

26

The role of WS under this alternative would be indirect : WS c ould provide advice to producers 27

on the use of non

- lethal methods

, c ould investigate wolf damage incidents and report results to 28

WDFW , and could conduct select nonlethal harassment

. WDFW makes the final determinations. 29

30

Non

- lethal Methods Available to WS, WDFW, USFWS, Tribes

, and the Public 31

32

Some wolf damage management methods are available for anyone to use. These consist of non

33

lethal preventive methods such as cultural practices ( e.g ., possible changes in livestock 34

management) and localized habitat modification ( e.g., clearing brush, improving fencing, etc.) on 35

private property. Cultural practices and other management techniques are implemented by the 36

resource owners / managers. Livestock producers and resource owners / managers are encouraged 37

to use these methods, based on the level of risk, need and professional judgment on their 38

effectiveness and practicality. WS’

, WDFW ’s , or USFWS’ involvement in the use of these 39

methods is usually limited to providing technical assistance. 40

41

Livestock Management Practices are implemented to prevent or reduce wolf damage and may 42

include approaches such as: 1) maintaining healthy, well

- fed animals, 2) properly disposing of 43

livestock carcasses ( i.e ., removal, burying, liming, or burning), 3) conducting calving or lambing 44

operations in close proximity to the ranch headquarters when practical, 4) penning vulnerable 45

livestock at night where practical, 5) mo nitoring livestock on a regular basis to detect any 46

disease, natural mortality, or predation, 6) keeping livestock away from areas of historic wolf 47

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activity, and 7 ) incorporating other non

- lethal methods. Property owners and land managers 1

could implement these management practices or request the assistance of other agencies or 2

private organizations to implement them, or take no action. 3

4

Exclusion with some type of fence or other barrier may be used to prevent or limit access by 5

predators to livestock pastu res, calving or lambing areas, or livestock confinement areas. Where 6

practical and cost effective

, sheep, calves

, or other vulnerable livestock may be penned near 7

ranch buildings at night. 8

9

Fladry is a form of barrier and wolf deterrent involving red flag s measuring approximately 3 x 10

18 inches, strung about 20 inches apart, hanging from a thin rope or cord suspended about 30 11

inches above the ground. Fladry is installed around pastures or other areas where livestock are 12

confined to discourage wolf access. Part of the repellency provided by fladry is probably related 13

to the frequent human visitation required to ensure that the flags remain freely suspended and 14

that the line is properly maintained. Like many other frightening devices, wolves eventually 15

habi tuate to this deterrent, but field trials in Idaho have shown that fladry may provide deterrence 16

for as long as 60 days (Musiani et al. 2003). Davidson

- Nelson and Gehring (2010) reported that 17

if maintained, fladry can exclude wolves from livestock for up to 75 days; however Shivik et al. 18

(2003) found that fladry did not effectively protect bait sites from scavengers, including wolves. 19

20

Turbo

- Fladry is very similar to regular fladry with the exception that the cord is substituted 21

with electrified wire attached to a standard livestock electric fence generator. As wolves 22

habituate to the fladry line and try to cross under it, the negative stimulus the y receive after 23

getting shocked by the electrified barrier can increase the amount of time the barrier may remain 24

effective. 25

26

Livestock guarding animals such as large, aggressive breeds of guarding dogs ( e.g ., Great 27

Pyrenees, Akbash, etc.) have been used w ith some success to protect livestock from wolves, but 28

multiple guard dogs work better than just one or two guard dogs (Bangs et al. 2005, Urbigkit and 29

Urbigkit 2010). Even with 3 or more dogs present, wolves occasionally kill or severely injure 30

livestock guarding dogs. Livestock guarding dogs are generally not killed as prey but because of 31

interspecies aggression (Bangs et al. 2005). Other types of livestock guarding animals, such as 32

llamas, which have been shown in some circumstances to be effective in protecting sheep from 33

coyotes, are not as effective in deterring wolves. Wolves probably view llamas as prey, and 34

multiple instances of wolves killing and feeding on llamas have been documented in the NRM 35

area (USFWS et al. 2003, 2008 , 2009, and 2010). 36

37

Guarding and hazing involves using human presence to guard an area and then using 38

pyrotechnics or other frightening devices to frighten wolves from the site if/when they arrive. 39

Hazing can be used as an aversive technique, but requires that the technique be used consistently 40

whenever the animal attempts to prey on the protected resource so they do not identify 41

conditions when they can obtain prey without receiving a negative experience (Shivik 2004). If 42

there are any radio

- collared wolves in a pack which may pose a threat to livestock, non

- lethal 43

hazing efforts can be enhanced if the livestock producer or other personnel make use of a radio 44

receiver to determine when wolves are near or approaching the livestock (Bangs et al. 2006). 45

This requires diligent and persistent monitoring, but can make hazing much more effective. 46

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Frightening devices are methods that usually involve lights, sound and/or motion devices 1

designed to deter wolves from a certain area. Strobes and flashing lights, propane exploders, 2

sire ns, and various combinations of these devices have all been used in attempts to reduce 3

livestock losses, with wide

- ranging degrees of effectiveness (Linhart 1984, Andelt 1987). 4

Animal habituation (becoming accustomed) to the stimulus is one of the primary limiting factors 5

for repellents. Essentially, anything new or different is likely to elicit avoidance behavior by 6

canids, but this effect iveness disappears over time. Moving the devices intermittently and 7

randomly as well as alternating the stimuli ( e.g ., a different type of noise or light) may extend the 8

effective period of the system (Shivik and Martin 2001). The period of efficacy may also be 9

extended by using systems which are motion

- activated or only activated when a wolf wearing a 10

transmitter coll ar comes into close proximity to the protected site. The RAG box is one such 11

frightening device that employs this approach, and RAG boxes have been field

- tested in Idaho 12

with some success (Breck et al. 2002). Use of the RAG box in Idaho has been most eff ective in 13

protecting livestock in small (≤60 acre), fenced

- in areas. 14

15

Non

- lethal Methods Available to WDFW

, USFWS

, and Tribes , but not WS 16

17

Some non

- lethal methods, research projects

, and population monitoring efforts involve capture 18

and handling wolves which may not be conducted by the general public. Methods that require 19

capture and handling of wolves under state authority would only be conducted by WDFW 20

personnel or agencies permit ted by the WDFW

. Sovereign tribal governments c ould act under 21

their own authority on sovereign tribal lands. 22

23

Foot

- hold traps can be effectively used to live capture wolves, and are an extremely important 24

tool in wolf damage management. When wolves are trapped they are ordinarily physically 25

restrained or chemically immobilized, radio

- collared, and released on site, or euthanized on site. 26

Effective trap placement, pan

- tension devices and the selection and placement of appropriate 27

lures and baits by trai ned personnel contribute to the foot

- hold traps’ selectivity. Traps may also 28

be modified with small protrusions or “nubs” on the jaws to reduce the likelihood of the wolf’s 29

foot moving back and forth in the jaws, thereby reducing the potential for trap

- re lated injury. 30

Washington State has a trap check rule in effect requiring that all foo thold traps be checked 31

every 24 hours. 32

33

Disadvantages of traps include the difficulty of keeping them operational during rain, snow or 34

freezing weather, and the fact that they cannot be 100% selective. Although pan

- tension devices 35

are effective in reducing the likelihood of unintentional capture of non

- target species smaller 36

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

37

tar get species such as cougars or black bears. They do, however allow for the option of releasing 38

non

- target animals which may infrequently be captured. 39

40

Foot snares are devices consisting of a cable loop and a locking device that captures an animal 41

around its foot or lower leg. The cable may be activated ar ound the lower leg with a spring

42

powered throw

- arm (Aldrich

- type) or trap

- type (Belisle) device. The foot snare can be modified 43

with a stop on the cable to restrict the closure of the loop. Careful sn are placement, pan

- tension 44

devices and the selection and placement of appropriate lures and baits by trained personnel 45

contribute to the selectivity of this device. As with foot

- hold traps, when foot snares are used as 46

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a live

- capture device, wolves would ordinarily either be radio

- collared and released on site, or 1

euthanized. Foot snares are more often used for capture of cougar s and black bears than for 2

wolves. Washington State has a trap check rule in effect requiring that all foot snares be checked 3

ev ery 24 hours. 4

5

Drug delivery tools are capture tools that utilize a dart or syringe filled with an immobilization 6

drug, dispensed from a specially

- designed device. These devices include hand or poll syringes, 7

blow guns, and compressed gas or gun

- powder charged systems. They would often be used on 8

wolves when conducting live

- capture operations from a helicopter. Once immobilized , the 9

animal may be handled safely and processed for research or monitoring purposes. Use of drug 10

delivery tools would have no effect on non

- target species because positive target species 11

identification is made before animals are darted. 12

13

Neck Snares can be used to kill

, or to live

- capture animals with a cable loop around the neck 14

and the use of a “stop” to prevent full closure of the loop . I mproved methods for use are being 15

developed for live

- trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 16

are ordinarily not as affected by rain, snow, and freezing weather as foot

- hold traps are. These 17

devices offer a degree of selectivity based on the size of the cable loop and the height of the loop 18

above ground level. They also offer a viable live

- capture alternative to foot

- hold traps during the 19

winter months, when freez ing temperatures combined with restricted blood circulation could 20

result in damage to the wolf’s foot. 21

22

Non

- lethal Methods which may Require Special Authorization from WDFW , USFWS, 23

and Tribes 24

25

These methods are not available to WS under this alternative (A lternative 1, NO Action). Some 26

animal behavior modification systems involve capturing and fitting wolves with radio

27

transmitting collars to deliver or trigger repellent stimuli ( i.e., aversive conditioning). Other 28

systems sometimes referred to as “less t han lethal munitions,” involve shooting wolves with 29

projectiles such as rubber bullets or bean bag rounds. These techniques involve intentionally 30

using painful stimuli to modify wolf behavior and WDFW and the USFWS may require permits 31

or other authorizati ons to use these methods and any other experimental wolf damage 32

management techniques. Methods that require capture and handling of wolves would be 33

conducted only by personnel from WDFW , USFWS, or tribes, and / or personnel authorized by 34

ei ther of these entities. 35

36

Aversive Stimuli are stimuli that cause discomfort, pain and/or an otherwise negative experience 37

paired with specific behaviors to achieve conditioning against these behaviors. One example 38

would be using something like a dog training shock coll ar that is activated when wolves come 39

into close proximity to a protected area such as livestock pens (Shivik et al. 2003, Schultz et al. 40

2005). 41

42

Non

- lethal Projectile use involves guarding an area and then using rubber bullets, bean bag 43

rounds or other no n

- lethal projectiles to prevent a predation event. They can be used as an 44

aversive technique, but require that the projectiles be used consistently whenever the predator 45

attempts t o prey on the protected resource, so it is less likely to identify conditio ns when it can 46

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obtain prey without receiving a negative experience (Shivik 2004). Methods which require 1

around

- the

- clock presence of a person to guard the resource are most efficiently used when there 2

are radio

- collared wolves involved and the landowner/r esource manager assists with the 3

implementation. WDFW authorizes t he use of these methods

. 4

5

For additional discussion of the advantages and disadvantages of various non

- lethal and lethal 6

wolf damage management methods used in the NRM, see Bangs et al. (20 06) 7

( http://www.aphis.usda.gov/wildlife_damage/nwrc/publications/06pubs/shivik067.pdf ). 8

9

Description of Lethal Methods Available to WDFW, USFWS, and Tribes, but not WS 10

11

These methods are specifically designed to lethally remove wolves in certain situations to 12

stabilize, reduce

, or eliminate damage. The amount of removal necessary to achieve a reduction 13

in wolf damage varies according to the effectiveness of o ther damage management strategies, the 14

damage si tuation, and the level and likelihood of continued depredations. There would be no 15

lethal wolf damage management techniques available to WS under Alternative 1, but the use of 16

foothold traps and snares, as described above , followed by euthanasia, typically by gunshot to 17

the brain, as recommended by the American Veterinary Medical Association ( AVMA 20 1 3

, 18

Julien et al. 2010) would be available to WDFW or its agents , USF WS, and tribes . Additional 19

lethal methods used under Alternative 1 would incl ude shooting from the ground as well as from 20

fixed

- wing aircraft or helicopters. 21

22

Shooting from the ground is highly selective for the target species, and may be employed in 23

conj unction with the use of auditory attractants ( e.g ., sounds of prey animals in distress or 24

imitations of wolf vocalizations). Removal of one or two specific animals by shooting in the 25

problem area can sometimes provide immediate relief from a predation pro blem. Shooting is 26

often tried as one of the first lethal management options because it offers the potential of solving 27

a problem more quickly and selectively than some other techniques, but it requires visually 28

sighting the wolf within effective shooting distance. Shooting may sometimes be one of the only 29

management options available if other factors preclude the setting of equipment ( i.e ., traps or 30

snares). 31

32

Aerial Shooting typically involves visually locating suspected depredating individuals or packs 33

f rom either a small single

- engine fixed

- wing aircraft or a helicopter, and shooting them from the 34

aircraft. Depredation problems can sometimes be resolved very quickly and effectively through 35

aerial shooting ( e.g ., by starting the aerial operation in the v icinity of a recent wolf kill and 36

catching the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) 37

rated aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of 38

adverse environmental impac ts. Smith et al. (1986) cited cost

- effectiveness and efficacy as 39

benefits of aerial shooting. 40

41

Good visibility is required for effective and safe aerial shooting operations, and relatively clear 42

and stable weather conditions are necessary. Summer conditi ons limit the effectiveness of aerial 43

shooting because the increased vegetative cover makes finding the animals more difficult, and 44

the higher ambient air temperatures reduce air density, which affects low

- level flight safety. 45

Aerial shooting is one of the most effective wolf damage management tools available. 46

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Sodium Pentobarbital (Beuthanasia®

- D) is registered for euthanasia of dogs, but may legally 1

be used for other animals if the animal is not intended for human consumption. Barbiturates 2

depress the cen tral nervous system in descending order, beginning with the cerebral cortex, with 3

unconsciousness progressing to death. The primary advantage of barbiturates is the speed of 4

action on the animal. Barbiturates induce euthanasia smoothly, with minimal disc omfort to the 5

animal (AVMA 20 1 3 ). This method of euthanasia would likely only be used in the rare 6

circumstance where an already sedated wolf was determined to have health or injury issues such 7

that it would be most appropriate to euthanize the animal. 8

9

Monitoring 10

11

WS provide s information on wolf sightings, identification of wolf activity (tracks or scat), 12

depredation investigations, telemetry searches, or any other monitoring activities. Wildlife 13

Services monitors its program activities using a national software program , Management 14

Information System ( MIS ), which compiles data on harassment locations, damages, methods 15

used, and other information. Information from MIS can then be provided to cooperating 16

agencies, used in wildlife management decisions and environmental analyses, and is available to 17

the public. 18

19

2.2 Alternative 2

– Eliminate the Current Wolf Assistance Program 20

21

U nder Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 22

not provide any wolf assistance to WDFW, USFWS, other public agencies, tribes, or private 23

individuals within Washington. WS would not distribute available equipment or assist 24

landowners with the implementation and use of non

- lethal methods and de vices. WS would not 25

investigate wolf depredation complaints to determine if the wolves are responsible for losses

. 26

WDFW would make the final determinations for investigations under their jurisdiction. WS 27

would not assist WDFW , USFWS, or tribes with capt uring wolves for radio

- collaring for 28

monitoring purposes and/or to enhance effectiveness of non

- lethal deterrents such as the RAG 29

devices

. 30

31

The WCMPW describe s measures WDFW w ould take to conserve and manage wolves, 32

i nclud ing actions that coul d be taken to protect livestock from wolf depredation . Alternative 2 33

encompasses all the primary components of the WCMPW and all actions and components listed 34

in Alternative 1, b ut removes WS as a n assisting agency to WDFW , USFWS, and tribes . While 35

the WCMPW refere nces WDFW using WS for assisting with wolf recovery, WS would not 36

ac tually participate in any wolf

- related actions under this alternative. WDFW , or its agents, 37

would have to redirect personnel from conducting wolf research, outreach, and recovery projects 38

to conducting wolf control and removal. WS would not be able to guarantee any mitigation 39

measures against the accidental impact to target and non

- target wildlife, public safety, or 40

personnel safety during wolf control activities conducted by others. 41

42

43

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- Wildlife Services’ Gray Wolf Damage Management In Washington 26CHAPTER 2. DESCRIPTION OF ALTERNATIVES

2.3 Alternative 3

– Proposed Action

– Expand the Current Wolf Assistance Program 1

2

This alternative would allow W S to use non

- lethal methods, capture wolves for monitoring or 3

translocation needs, and respond to requests by WDFW or tribes to lethally remove non

- federally 4

listed depredating wolves , and with the addition of USFWS, wolves jeopardizing public safety as 5

outlined in the WCMPW or similar guidance (e.g., ESA and CFR) . Wolves could be removed 6

after a request from WDFW or tribes based on confi rmed livestoc k depredation and after 7

unsuccessful attempts using non

- lethal methods had been documented. The proposed action 8

encompasses all of the methods discussed in Alternative 1 with WS conducting the direct 9

activities

. 10

11

The role o f WS in this program would be direct : WS would conduct a fully integrated approach 12

to wolf damage management, as requested by WDFW , USFWS, or tribes under the guidance of 13

the WCMPW or similar guidance

. WDFW would maintain responsibility for making the fin al 14

determinations on removal of federally delisted wolves, USFWS would retain management of 15

federally listed wolves, and tribes would maintain management of wolves on tribal lands. WS 16

wolf damage management on tribal lands would mirror procedures and rest rictions on non

- tribal 17

lands, with the exception that tribal wildlife managers or WS may confirm wolf damages. 18

19

As per W S policy, it would only provide direct w olf damage management on properties after 20

Agreement for Control or other work authorization docu ments have been completed. On federal 21

public lands, p lanned activities must be included in work plans developed in coordination with 22

each National Forest or BLM Resource Area, or in emergency, unplanned situations, in 23

consultation with the respective USFS or BLM office. On tribal reservation lands, WS wolf 24

damage management would only be conducted at the request of the tribe and under individual 25

agreements with each sovereign tribal government. 26

27

Like Alternative 1 , the Current Program , a strong information and education program , which 28

focuses on nonlethal management, would be managed by WDFW with assistance from WS. 29

This aspect would help ensure anyone with an interest in wolves is able to learn more about the 30

species and stay informed a bout wildlife management activities . The WCMPW includes 31

examples of education on wolf damage management issues such as public outreach, public 32

meetings, information on the WDFW website, training, and discussions with individuals. 33

34

Several research projects are identified as necessary for future success of long

- term wolf 35

conservation and management. Monitoring and radio

- collaring wolves would be included in this 36

alternative for conservation and communication with the public . WS may assist in capturing 37

wolv es for radio

- collaring. 38

39

Adaptive management would be used by WDFW to revise protocol according to changes in the 40

phase of wolf recovery in Washington

. Over time, wolves are expected to increase in number 41

and expand their range within Washington, and therefore management approaches will be 42

slightly modified as numbers increase ( Wiles et al. 2011). 43

44

Finally, the WCMPW requires annual reporting to the WDFW on program implementation , thus 45

WS would provide all information on its involvement with wolf captu res including capture 46

locations, methods used , and disposition to WDFW

. 47

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Formulating a strategy for wolf removal 1

2

Upon receiving a request to assist WDFW , USFWS, or tribes with capturing individuals from 3

packs with confirm ed repeated depredating wolves, WS would use its Decision M odel (Figure3) 4

(S late et al. 1992) to determine the appropriate method of removal based on allowable methods 5

(foot

- hold traps, foot snares, neck snares, shooting, or aerial shooting) under the WCMPW , or 6

similar guidance, and cons ultation with WDFW , USFWS, or tribes

. 7

8

Figure 3. APHIS

- WS Decision Model (Slate et al. 1992) 9

In selecting appropriate management techniques

, consideration is given to: whether or not a 10

collared or breeding wolf could be affected, location and land jurisd iction; land uses (such as 11

proximity to urban or recreation areas); possible presence of humans, pets and non

- target 12

wildlife ; feasibility of implementation of the various techniques; wolf movement patterns and 13

life cycle; local environmental conditions su ch as terrain, vegetation, and weather; potential legal 14

restrictions such as availability of tools or management methods; humaneness of the available 15

options; and costs of control options (the cost of control in this proposal may be a secondary 16

concern bec ause of overriding environmental, management, and legal considerations). 17

18

W hen responding to requests from WDFW or tribes, l ethal removal of wolves from packs 19

causing repeated livestock depredation would only be done after unsuccessful attempts to use 20

non

- lethal methods ha d been documented. While the WCMPW dictates this for WDFW, WS 21

would only agree to lethal removal on tribal lands under similar guidance

. 22

23

Description of Lethal Method s Available to WS 24

25

This alternative includes all non

- lethal methods described in Alternative 1, the Current Program, 26

and adds the following lethal methods. These methods are specifically designed to lethally 27

remove problem wolves in certain situations to stabilize, reduce, or eliminate damage. The 28

amount of removal necessary to achieve a reduction in wolf damage varies according to the 29

effectiveness of other damage management strategies, the damage situation, the level and 30

likelihood of continued depredations , and WDFW or t ribal final decision

. The lethal wol f 31

damage management techniques available to WS would include the use of foothold traps and 32

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- Wildlife Services’ Gray Wolf Damage Management In Washington 28CHAPTER 2. DESCRIPTION OF ALTERNATIVES

snares

, followed by euthanasia, as recommended by the American Veterinary Medical 1

Association ( AVMA 20 1 3 , Julien et al. 2010). Additional lethal methods used under Alternative 2

3 would incl ude shooting from the ground as well as from fixed

- wing aircraft or helicopters. 3

4

Shooting highly selective for the target species, and may be employed in conjunction with the 5

use of auditory att ractants ( e.g ., sounds of prey animals in distress or imitations of wolf 6

vocalizations). Removal of one or two specific animals by shooting in the problem area can 7

sometimes provide immediate relief from a predation problem. Shooting is often tried as on e of 8

the first lethal management options because it offers the potential of solving a problem more 9

quickly and selectively than some other techniques, but it requires visually sighting the wolf 10

within effective shooting distance. Shooting may sometimes be one of the only management 11

opti ons available if other factors preclude the setting of traps or snares. 12

13

Aerial Shooting typically involves visually locating suspected depredating individuals or packs 14

from either a small single

- engine fixed

- wing aircraft or a helicopter, and shooting the m from the 15

aircraft. Depredation problems can often be resolved quickly and effectively through aerial 16

shooting ( e.g ., by starting the aerial operation in the vicinity of a recent wolf kill, and catching 17

the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) rated 18

aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of adverse 19

environmental impacts. Smith et al. (1986) cited cost

- effectiveness and efficacy as benefits of 20

aerial shooting. 21

Good visibility is required for effective and safe aerial shooting operations, and relatively clear 22

and stable weather conditions are necessary. Summer conditions limit the effectiveness of aerial 23

shooting because the increased vegetative cover makes fin ding the animals more difficult, and 24

the higher ambient air temperatures reduce air density, which affects low

- level flight safety. 25

Aerial shooting is one of the most effective wolf damage management tools available. 26

27

Neck Snares can be used to kill

, or to live

- capture animals with a cable loop around the neck 28

and the use of a “stop” to prevent full closure of the loop . I mproved methods for use are being 29

developed for live

- trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 30

are ordina rily not as affected by rain, snow, and freezing weather as foot

- hold traps are. These 31

devices offer a degree of selectivity based on the size of the cable loop and the height of the loop 32

above ground level. They also offer a viable capture alternative t o foot

- hold traps during the 33

winter months, when freezing temperatures combined with restricted blood circulation could 34

result in damage to the wolf’s foot. 35

36

Sodium Pentobarbital (Beuthanasia®

- D) is registered for euthanasia of dogs, and may legally 37

be use d for other animals if the animal is not intended for human consumption. Barbiturates 38

depress the central nervous system in descending order, beginning with the cerebral cortex, with 39

unconsciousness progressing to death. The primary advantage of barbitur ates is the speed of 40

action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the 41

animal ( AVMA 2013 ). This method of euthanasia would likely only be used in the rare 42

circumstance where an already sedated wolf was determin ed to have health or injury issues such 43

that it would be most appropriate to euthanize the animal. 44

45

46

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Measures used by WS to Minimize Environmental Risk 1

2

W S uses many standard operating procedures built into its programs which serve to minimize the 3

potential for negative effects on the environment, including potential harm to humans and non

4

target wildlife. While the WCMPW may be updated and permit conditions can change, 5

c urrently, WS standard operating procedures, the WCMPW and /or WDFW permit c onditions 6

and conservation measures include, but are not limited to the following measures: 7

8

• Conspicuous, bilingual warning signs alerting people to the presence of traps and snares are 9

placed at major access points when they are set

. 10

11

• W S personnel are tra ined in identification of wolves and wolf sign. 12

13

• W S will maintain regular contact with appropriate state and federal agencies, report ing any 14

sightings of wolves, wolf sign, or wolf depredations

. 15

16

• WS will monitor traps every 24 hours while using foothold traps or snares. 17

18

• WS will incorporate pan

- tension devices in foot/leg snares and foot

- hold traps to reduce 19

exposure of capture to smaller non

- target animals. 20

21

• W S will maintain re gular contact with WDFW , USFWS, and/or tribes to keep apprised of 22

locations and information on the presence of any T&E animals. 23

24

• Most wolf trapping will occur at or near depredation sites or along wolf trails to and from 25

depredation sites. 26

27

• Non

- target animals captured are released at the site of capture unless the W S personnel 28

determine that they will not survive. 29

30

• AVMA (20 1 3 ) recommended euthanasia procedures are followed, if feasible, to minimize 31

pain and suffering. 32

33

• Research continues to improve the selectivity and humaneness of manag ement devices. 34

35

• WS work on Native American Indian tribal lands would conform to tribal government 36

plans for wolf damage management. WS work on tribal lands would also closely mirror 37

protocol outlined in WCMPW in regards to lethal and non

- lethal management of wolf 38

depredation. 39

40

• W S records and monitors all WS wolf removal through its Management Information 41

System (MIS) . Close coordination with and reporting to WDFW

, USWFS , and/or tribes would 42

occur for each wolf to be removed. More detail is provided under Mo nitoring in this section. 43

44

• Motorized v ehicle access on public lands will be limited to permitted roads and areas. 45

46

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• Wolf damage management activities would be conducted only at the request of, and in 1

coordination with the landowner or land management agency , and in the case of lethal control, 2

per WDFW , USFWS, or tribal government decisions. Coordination provides for the 3

communication necessary to avoid conflicts with land uses such as sensitive areas or public 4

safety zones. 5

6

• Th e WS program is conducte d under Cooperative Agreements and MOUs with federal and 7

state agencies. National MOU’s with the BLM (1995) and USFS (2010) delineate expectations 8

for wildlife damage management on public lands administered by these agencies. 9

10

General Measures to Protect F ederally Threatened or Endangered Species 11

• In accordance with WS policy, f oot

- hold traps and foot snares would be placed 12

farther than 30 feet from exposed carcasses to avoid inadvertent capture of 13

eagles. 14

• WS WA would prioritize control methods to be used and would include 15

consideration of non

- target species in making these decisions. Where non

16

target species of concern may be vulnerable, selective measures are generally 17

preferred (such as shooting or darting). For large animals, culvert or cage traps 18

may be preferred over other trapping methods. Foot

- hold traps and foot snares 19

are generally preferable to neck snares except under certain environmental 20

conditions. WS WA will fully consider risk to non

- target species in making 21

these decisions. 22

• When conduct ing trapping, WS WA staff will consider target species, non

23

target species, site

- specific conditions, as well as all policy and regulatory 24

requirements in determining types of traps, sets, lures or scents, and supporting 25

hardware. The decision on whether to use a drag or stake will follow the 26

considerations discussed earlier in the project description. 27

• WS WA staff that are trapping large predators (e.g., wolves, cougars, and black 28

bears), in areas where and when grizzly bear are reasonably likely to be pr esent, 29

will be trained in the identification of large predators (particularly in 30

distinguishing between black bears and grizzly bears) and their sign. Training 31

conducted by WS WA may be done in collaboration with the local USFWS or 32

WDFW offices, or in con junction with WS in other states. 33

• Mapped landscape areas (designated for pygmy rabbit, lynx, grizzly bear, or 34

federally listed wolves) will be reviewed on an annual basis with USFWS, 35

WDFW, and other appropriate species experts to determine if an increase

, 36

decrease, or other modification is necessary. Applicable section 10(a)(1)(A) 37

permits will be reviewed at that time to ensure continued applicability and 38

listing of appropriate staff. 39

• Prior to trapping within mapped landscape areas (designated for lynx, grizzly 40

bear, or federally listed wolves), WS WA will contact USFWS and/or WDFW 41

for the most

- recent information regarding the distribution of these species. WS 42

WA will conduct pre

- trapping reconnaissance in a manner that is directed 43

toward finding sign of these species and will report any positive findings to 44

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WDFW and USFWS. Personnel conducting such pre

- trapping reconnaissance 1

will be adequately trained in the identification of sign left by these species. 2

• Where pre

- trapping reconnaissance discovers recen t signs of certain species, or 3

pre

- trapping coordination reveals recent reliable observations of those species 4

(i.e., grizzlies or lynx), alternative methods that are more selective will be used 5

in lieu of trapping unless otherwise approved on a case

- by

- ca se basis by the 6

USFWS after considering public safety and animal welfare. 7

• When trapping in grizzly bear, lynx, or federally listed wolf mapped landscape 8

areas, or trapping for federally listed wolves, traps or snares should be checked 9

by mid

- morning, or as soon thereafter as possible in case of extenuating 10

circumstances. 11

12

Measures Specific to Federally Listed Gray Wolves 13

• When doing pre

- trap or operational reconnaissance for federally listed wolves 14

and sign in areas that may contain wolves, howling will be c onducted to 15

facilitate detection if it is appropriate for the surroundings. 16

• While targeting coyotes and other predators, and where pre

- trapping 17

reconnaissance discovers recent sign or pre

- trapping coordination reveals recent 18

reliable observations of federally listed wolves, WS WA may resort to non

19

trapping alternatives to achieve their objectives if capture of a wolf in that area 20

is not deemed to be desirable. When capture of a wolf is deemed desirable by 21

WS WA and wildlife agencies, WS WA will follo w appropriate protocols 22

provided by the wildlife agencies and all conservation measures that apply in 23

case they inadvertently capture a wolf. 24

25

When operating within a mapped landscape area for federally listed wolves, WS 26

will implement the following: 27

28

• Init ial mapped landscape areas for federally listed wolves shall be the pack 29

polygons maintained by WDFW and depicted on the WDFW website 30

( http://wdfw.wa.gov/conservation/gray_wolf/packs/ ). Thes e may change on 31

a frequent basis as wolf distribution changes. Whether this system is 32

working adequately will be assessed on an annual basis. 33

34

• Prior to controlling coyotes and other predators, WS WA would coordinate 35

closely with USFWS and/or WDFW to ensur e that field personnel have the 36

most recent and most

- reliable information on wolf activity in the action 37

area. WS WA would conduct pre

- trapping reconnaissance in a manner to 38

detect any potential wolf sign prior to setting traps; this may include 39

howling w hen appropriate. 40

• When controlling predators smaller than wolves, traps and equipment must 41

be of sufficient strength to adequately restrain any wolf without equipment 42

failure, or allow the wolf to pull free from the trap. Stakes will be preferable 43

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- Wildlife Services’ Gray Wolf Damage Management In Washington 32CHAPTER 2. DESCRIPTION OF ALTERNATIVES

in thes e situations as staking may allow a captured wolf to pull

- out of the 1

trap more easily. 2

• When conducting predator control, no traps or snares shall be used within 3

0.5 mile of occupied federally listed wolf den sites, known active 4

rendezvous sites, or areas of recently documented pup activity from May 1 5

to July 15, and within 1 mile of these ar eas from July 15 to October 1, 6

unless approved on a case

- by

- case basis by the USFWS. 7

• When conducting predator control, neck snares will not be used in mapped 8

landscape areas without prior approval by USFWS. 9

10

When trapping federally listed wolves, WS will implement the following: 11

• No traps or snares shall be used within 0.5 mile of occupied federally listed 12

wolf den sites, known active rendezvous sites, or areas of recently 13

documented pup activity from May 1 to July 15, and within 1 mile of these 14

areas fro m July 15 to October 1, unless approved on a case

- by

- case basis by 15

the USFWS. 16

• Neck snares will not be used to capture federally listed wolves unless such 17

use is approved by USFWS. 18

• Foot

- hold traps will not be used to capture federally listed wolves in 19

nig httime temperatures below 25°F unless otherwise approved by USFWS. 20

• When live capturing federally listed wolves, WS WA will use Livestock 21

Protection Company #7 offset jaws or EZ

- grip ® traps or equivalent, unless 22

otherwise approved by the USFWS. At least 2 swivels will be used (one at 23

trap and one at drag or stake). 24

• WS WA will ensure, in advance, that a means of safe transport for federally 25

listed wolves (e.g., a large kennel) is rea dily available if medical treatment 26

should be necessary. 27

• WS WA staff that capture federally listed wolves will be trained in chemical 28

immobilization and handling of wolves, or will be accompanied by WS WA 29

staff that have been so trained. 30

• This consultation will not supplant or replace any other reporting 31

requirements or informational commitments. WS will adhere to any 32

guidelines and protocols cooperatively developed among WS WA, WDFW, 33

and USFWS regarding responding to sightings, captures, mortalities, 34

info rmation about illegal activities, or other reports of gray wolves in 35

Washington State. 36

37

• When WS WA purposefully or incidentally captures federally listed wolves, 38

in addition to adhering to the Response Guidelines, such capture will be 39

managed in the following manner: 40

o If the wolf is dead, WS will transport the carcass from the field and 41

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report the death to the USFWS Washington Fish and Wildlife Office 1

wit hin 24 hours for data collection and disposal. The carcass will be 2

kept as cold as feasible to preserve its integrity. 3

o If the wolf will not be able to survive in the wild and should be 4

euthanized on site, the most

- expedient means of euthanasia shall be 5

em ployed consistent with the surroundings and situation. Following 6

euthanasia, WS will transport the carcass from the field and report to 7

the USFWS Washington Fish and Wildlife Office so that they can 8

cooperatively collect data and dispose of carcass. The carcass will 9

be kept as cold as feasible to preserve it integrity. 10

o If the wolf requires veterinary medical attention and transport is 11

necessary and feasible, WS will pursue veterinary medical care and 12

notify the USFWS Washington Fish and Wildlife Office fo r 13

instructions regarding the best course of action following such care. 14

If the wolf is a candidate for release, the details of such release shall 15

be determined cooperatively with the WDFW and the USFWS. 16

o If the wolf is essentially uninjured and is a good c andidate for further 17

research, WS will follow protocols provided by the USFWS and 18

WDFW for collecting samples, data, and any fitting with 19

instrumentation. Chemical immobilization shall only be done by 20

personnel experienced with handling wolves and certifi ed to 21

administer chemical immobilization drugs, unless otherwise 22

approved by USFWS. 23

o If the wolf is uninjured and no research is needed, WS will release 24

the wolf as expeditiously as possible in a manner that protects the 25

wolf and maximizes its chances for successful release and survival. 26

Steps outlined in applicable protocols shall be followed. In some 27

cases, this may require restraint and or chemical immobilization. 28

Chemical immobilization shall only be done by personnel 29

experienced with handling wolve s and certified to administer 30

chemical immobilization drugs, unless otherwise approved by 31

USFWS. 32

33

Measures Specific to Grizzly Bear 34

• When conducting predator control and where pre

- trapping reconnaissance or 35

pre

- trapping coordination with USFWS or WDFW revea ls sign of grizzly bear 36

or recent reliable observations, WS WA would resort to non

- trapping 37

alternatives to achieve their objectives unless otherwise approved on a case

- by

38

case basis by the USFWS after considering public safety and animal welfare. 39

40

• WS WA staff conducting trapping for large predators (wolves, cougars, or black 41

bears) in areas where and when grizzly bear are expected to be present will 42

carry a copy of a grizzly bear protocol including contact numbers and will 43

follow its instructions in the event a grizzly bear is captured. In the event that 44

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WS WA captures a grizzly bear, WS WA shall contact USFWS [Grizzly Bear 1

Coordinator at (406) 240

- 6506] and an appropriate representative from WDFW. 2

Arrangements would then be made to provide personn el from USFWS and/or 3

WDFW to assist with handling the bear and determining the fate of the animal 4

following the interagency guidelines already in place for recovery areas. 5

6

When operating within the grizzly bear mapped landscape areas during times 7

that gri zzly bears are expected to be out of the den (1 April to 30 November), 8

WS WA will implement the following: 9

10

• Initial mapped landscape areas for grizzly bear will be the Federal lands 11

within the North Cascades Recovery Zone; all lands within WDFW Game 12

Manage ment Units 108, 111, and 113; and all lands within the “Wedge” 13

(named after the wedge

- shaped part of northwestern Stevens County on the 14

Canadian border between the Kettle and Columbia Rivers)(Game 15

Management Unit 105). The mapped landscape areas and measu res 16

followed within those areas may increase, decrease, or change on an annual 17

basis following review with the wildlife agencies and others. 18

19

• WS WA would contact WDFW and USFWS to obtain most

- recent grizzly 20

distribution information. 21

22

• WS WA would conduct pre

- trapping reconnaissance in a manner sufficient 23

to detect any potential grizzly sign prior to setting traps. Where pre

- trapping 24

reconnaissance discovers recent signs of grizzly bear or pre

- trapping 25

coordination reveals recent reliable observations, WS WA would resort to 26

non

- trapping alternatives to achieve their objectives unless otherwise 27

approved on a case

- by

- case basis by the USFWS after considering public 28

safety and animal welfare. 29

30

• WS WA staff participating in trapping of large predators (wolves, cougars, 31

or black bear) will be trained in the identification of grizzly bears 32

(particularly in distinguishing between black bears and grizzly bears) and 33

grizzly bear sign. 34

• Staff participa ting in trapping of large predators (wolves, cougars, or black 35

bear) will be trained in implementation of techniques to avoid accidentally 36

trapping grizzly bears. 37

• WS WA staff conducting capture of large predators (wolves, cougars, or 38

black bear) will have been trained in chemical immobilization and in 39

handling of large predators, or will be accompanied by WS WA staff that 40

have been so trained. 41

42

• Use of foot snares and foot

- hold traps for wolves, cougars, or black bears 43

will be limited. 44

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o WS WA would prioriti ze the methods to be used with more

- selective 1

methods (e.g., shooting or aerial darting) being preferable. 2

Generally, more

- selective measures are attempted first in an overall 3

step

- wise progression of control. 4

o If no recent sign or knowledge of recent ob servations exists, WS 5

WA may use foot snares and/or foot

- hold traps within the mapped 6

landscape area. WS WA would provide written notification to 7

USFWS (electronic mail is acceptable) in advance (or within 72 8

hours if advance notice is not possible) that would include 9

demonstration of why such use is necessary in that particular 10

situation as well as any prior methods that were attempted during the 11

current control effort. 12

o WS WA will report, annually, the extent and results of such 13

trapping, the rationale for the use of foot

- hold traps or foot snares, 14

any prior methods that were attempted, and the timing and extent of 15

coordination with USFWS. 16

o Such notifications will not be necessary when trapping wolves 17

within the range of the federally listed wolf becaus e coordination 18

and notification will occur concurrently with the USFWS request to 19

do such work. 20

• Neck snares will not be used for any species without prior approval on a 21

case by case basis by USFWS, except for trapping coyotes within the 22

following developed areas such as airports, urban/suburban developments, 23

and animal

- husbandry operations. For purposes of this measure, animal

24

husbandry operations include, for example, barnyards, corrals, poultry 25

operations, animal enclosures, and similar operations near h ouses. When 26

used in these situations, neck snares will be placed judiciously to avoid areas 27

a grizzly bear or cub could reach or access. Appropriate neck snare 28

locations may include coyote crawl

- ways under fences or buildings. 29

• When using formulated or co mmercial scents at trap sites, WS WA would 30

utilize scents that are less attractive to grizzly bears (e.g., wolf urine vs. 31

scents resembling natural bear foods). 32

• Where possible and practical, wolf traps would be anchored to a solid 33

anchor such as a tree or, if such anchorage is not possible, to drags of at 34

least 500 pounds dead weight or Livestock Protection Company ® heavy

35

duty drag. 36

• If foot snares are used for the capture of black bears, wolves, or cougars, all 37

snares used will be grizzly sized snares with 1⁄4

- inch steel cables anchored to 38

fixed positions, and equipped with appropriate swivels. This is to ensure 39

that if a grizzly bear is unintentionally captured the snare will hold the 40

animal (rather than breaking away from the anchor and the grizzly bear 41

es caping with the snare remaining on the leg) until it can be safely 42

immobilized and released. 43

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Monitoring 1

2

Wildlife Services role in monitoring would be to provide data to WDFW , USFWS, or tribes from 3

its wolf damage management actions in Washington. Additionally

, WS would provide 4

information on wolf sightings, identification of wolf activity (tracks or scat), depredation 5

investigations, telemetry searches, or any other monitoring activities. Wildlife Services monitors 6

its program activities by using MIS

, which compiles data on take locations, damages, methods 7

used, and other information. Information from MIS can then be provided to cooperating 8

agencies, used in wildlife management decisions and environmental analyses, and is available to 9

the public. 10

2.4 Summary of Actions allowed by Alternative 11

12

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

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

13

Table 1 identifies and compares the major components allowed under each of the alternatives. 14

Specific criteria or conditions for actions, as required by the WCMPW, are summarized under 15

the detailed descriptions of each alternative. 16

17

18

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2.5 Alternatives Considered but Rejected from Detailed Analysis, with Rationale 1

2

Integrated W olf D amage Ma nagement without a T hreshold of L oss R equirement 3

4

This alternative would differ from the proposed action in that it would have removed the 5

threshold of livestock loss imposed by the WCMPW for agency removals of confirmed repeated 6

depredating wolves. Under this alternative, WS would be able to remove wolves that simply 7

threatened livestock or had killed fewer than the allowed threshold of loss. This a lternative is 8

not a viable alternative and cannot be selected based on the direction outlined in the WCMPW. 9

Wolves are not yet sufficiently abundant in Washington to allow for more liberal removal actions 10

and all actions must conform to the strategies all owed by the State. There is some flexibility in 11

the WCMPW that would allow producers to take wolves under permit which enhances agency 12

actions. This alternative may interfere with WDFW’s ability to achieve wolf conservation and 13

management goals. 14

15

Use of Birth Control Strategies to Reduce Wolf Depredation on Livestock 16

17

Under this alternative, wolves would be sterilized or other contraceptive methods would be 18

administered to limit the ability of wolves to produce offspring under the assumption that 19

inabilit y to reproduce would reduce wolf depredation on livestock. This strategy may interfere 20

with WDFW and USFWS goals for conservation and delisting of gray wolves. In USDA 21

(2011a), WS considered wolf contraception strategies that involve removal of all wolve s in a 22

pack that had caused repeated livestock depredation with the exception of the breeding pair, 23

which would be live

- captured, surgically sterilized, radio

- collared, and released under the 24

assumption that the pair would maintain and defend its territory against other wolves. WDFW 25

has not considered or included any wolf contraception strategies in the WCMPW

, nor does WS 26

have the authority to implement or require WDFW or the USFWS to test or implement such 27

strat egies. 28

29

Eradication 30

31

This alterna tive would direct all WS program efforts toward planned, tota l elimination of wolves. 32

This a lternative was not considered in detail because e radication of established wolf populations 33

is contrary to state and federal effor ts to protect and conserve wildlife and contrary to federal and 34

state ESA requirements

, WS objective is to reduce damage, not to engage in large

- scale 35

eradication or suppre ssion, and e radication of wolves is not acceptable to most members of the 36

public. 37

38

A gencies Exhaust All Non

- lethal Methods Before Attempting Lethal Methods 39

40

Under this a lternative, all non

- lethal methods would have to be attempted and proven ineffective 41

prior to using lethal wolf damage management methods even though, in the professional 42

judgment of WS

, WDFW , or USFWS personnel, some methods that would have to be attempted 43

would be impractical ( e. g ., would incur costs in excess of value of resources protected), 44

inappropriate ( e.g., use of a light siren device in areas near human residences)

, or likely to be 45

ineffective for the particular situation ( e.g ., situations where the predator appears to hav e 46

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habituated). This a lternative will not be addressed in detail for a number of reasons including: 1) 1

time and resources of agencies and individuals experiencing damage may be unnecessarily 2

expended when non

- lethal methods are unlikely to be effective, ba sed on circumstances, 3

experience and professional judgment; 2) the potential that additional losses could be incurred 4

while experimenting with non

- lethal methods; and 3) experimenting with non

- lethal approaches 5

may not be appropriate in the rare instance o f a wolf

- related threat to human safety. 6

7

Lethal Only Program 8

9

Under this Alternative WS would only provide technical and operational assistance with lethal 10

damage management techniques. In certain situations, non

- lethal methods may provide short

11

term or l ong

- term solution to wolf damage problems

. Prohibiting WS from using or providing 12

technical assistance on effective and practical non

- lethal wolf damage management methods is 13

not in the best interest of the continued recovery of the species and is contrar y to agency policy 14

and directives (WS Directive 2.101). 15

16

Sport Hunting and Trapping to Resolve Damages 17

18

WS has no authority to authorize or deny hunting or trapping season for wolves, nor is this 19

allowable under federal ESA regulations. T his issue is ou tside the scope of any decision that WS 20

would make as a result of this EA. 21

22

Live C apture and R elocation of Depredating W olves

. 23

24

When individual wolves or wolf packs are already established as repeated depredators of 25

livestock, moving them to another location may pose a high risk that the wolves would simply 26

cause livestock predation losses in their new area. Wolves can and often do move long distances 27

in relatively short periods of time and cannot be expected to stay in areas to which they are 28

relocated. Thus, even if wolves could be relocated to remote wilderness or sparsely inhabited 29

areas away from livestock, they cannot be relied upon to stay in such areas and avoid further 30

livestock depredation p roblems. WS has no authority to authorize or require WDFW, USFWS, 31

or tribes to choose this alternative , and this issue is outside the scope of any decision that WS 32

would make as a result of this EA. 33

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### CHAPTER 3

- ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS 1

2

3.1 Issues Driving the Analysis 3

4

T he following environmental issues or resources have been evaluated in this EA to help 5

determine the impacts of the proposed action on the environment and to compare the alternative s 6

in Chapter 4

. 7

8

• Impacts on wolf populations

- What might be the impact of the proposed action be on the 9

growing Washington wolf population, in eastern Washingto n and statewide? What would be 10

the cumulative effects of the proposal? 11

12

• Impacts on non

- target animals and human safety

- Would there be impacts on other 13

species besides wolves? Could the program affect pets? Might t he program have adverse or 14

beneficial effects on federally protected species? Are there risks to human safety? 15

16

• Social and Aesthetic Perspectives

– How acceptable are the alternatives to stakeholders? 17

How is humaneness perceived? What are the implicatio ns for the aesthetic value of wolves? 18

19

• Effectiveness

– A discussion on the effectiveness of the alternatives will reveal how well the 20

alternative meets the purpose and need for action. This issue is not an environmental issue, 21

but it is an important management consideration that will be weighed with the environmental 22

findings to make an informed decision. 23

24

3.2 Issues Not Analyzed in Detail

, with Rationale 25

26

Appropriateness of preparing an EA (rather than an EIS) for a state program rather than 27

preparing multiple EAs for smaller, more site

- specific areas 28

29

Federal agencies have the discretion to determine the geographic scope of their NEPA analyses 30

[ Kleppe v. Sierra Club, 427 U.S. 390, 414 (1976)] and WS has determined that preparatio n of 31

this EA to address wolf damage management in Washington is appropriate and consistent with 32

state ( Wiles et al. 2011 ) and federal wolf management objectives and plans. If a determination is 33

made through this EA

, that the proposed action would have a s ignificant impact on the quality of 34

the human environment, then an EIS may be prepared in compliance with NEPA. 35

36

Effects of wolf removal on a pack structure 37

38

Pack resilience to mortality is inherent in wolf behavioral adaptation and reproductive 39

capabilities (Brainerd et al. 2008). Wolf populations have sustained human

- caused mortality 40

rates of 30 to 50% without experiencing declines in abundance (Keith 1983, Fuller et al. 2003). 41

In addition, Brainerd et al. (2008) found that 62% of packs in recovering populations retained 42

territories despite breeder loss, and of those that lost territories, one

- half became re

- established. 43

P up survival is primarily dependent on size of pack and age of pup because multiple pack 44

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members feed pups despite loss of a breeder. Pup survival in 84% of packs with breeder loss 1

was similar or higher than packs without breeder loss (Mech and Boitani 2003). 2

3

WDFW , USFWS, or tribes are res ponsible for determining when a wolf shall be removed from a 4

pack. This will occur whether WS assists with removal or not. 5

6

Ecological effects of wolf removals 7

8

Wolf removal during damage management actions , combined with other forms of mortality, 9

would n ot result in a negative effect to wolves in WA , because if WS did not remove the wolf, 10

WDFW would conduct the removal or contract with a private party to conduct the removal. 11

Wolf removal as a mechanism of wolf damage management is expected to support wolf 12

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

. 201 1 )

. Based on a 13

review of available literature in USDA (2011 a )

, and Mech (2012) , we find no reason to expect 14

that wolf removals by WS would result in significant adverse effects on the quality of the human 15

environment because of possible wolf

- related changes in ecosystems. 16

17

WDFW, USFWS, or tribes are responsible for determining when a wolf shall be removed from a 18

pack. This will occur whether WS assists with removal or not. 19

20

Producers should consider that wolf predation losses a re a cost of doing business 21

22

Livestock producers recognize that some level of predation losses are likely to occur, in spite of 23

their own and government (state or federal) efforts to reduce the amount o f losses. The 24

WCMPW is not setting expectations of preventing all losses , nor does it prescribe lethal wolf 25

damage management as a solution to all depredation incidents. The WCMPW established an 26

integrated approach to resolve wolf damage complaints. In some situations

, the use of non

- lethal 27

methods alone may be adequate for resolving wolf depredation complaints, but there will be 28

situations which require lethal measures. Most instances of wolf predation on sheep, for 29

example, occur in spite of sheep producers’ use of herders and livestock g uarding dogs to help 30

protect the sheep from predation. Livestock producers incur direct losses and indirect losses 31

from wolves without always resulting in wolf removal. These includ e harassment of livestock 32

by wolves

, fence repairs after wolves chase liv estock through fences

, costs to gather and re group 33

livestock dispersed by wolves

, and extra costs when producers have to pay for feed because 34

livestock are removed from grazing pastures to minimize risks from wolves. These and other 35

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

. 36

37

Tribal Lands 38

39

Tribal wildlife managers with responsibilities to protect and manage treaty

- reserved wildlife 40

resources in Washington may meet wolf management needs in their areas of interest and 41

infl uence. Tribal leaders may choose how to manage wolf issues within their lands and may or 42

may not coordinate with the WCMPW

. 43

44

WS contacted the 29 federally recognized t ribes in Washington to solicit tribal concern s for this 45

EA. No issues were provided from these tribes. Because extensive outreach occurred during the 46

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preparation of the WCMPW , no new issues ar ose from the outreach and consultation associated 1

with this EA. 2

3

As discussed under the proposed action, WS determined that WS work on tribal lands would 4

conform to similar depredation management protocol s as allowed under the WCMPW and 5

USFWS regulations . Therefore, work on tribal lands in Washington would not add new issues or 6

change the analysis of effects considered in det ail. 7

8

Effects on Wilderness, Wilderness Study Areas, National Parks, State Parks

, and National 9

Monuments 10

11

Wolf removals would not occur in National Parks or National Monuments . Because individual 12

wolves may be removed from surrounding areas, the potential for a slight temporary effect on 13

users of National Parks and National Monuments may occur by reducing the opportunity to view 14

or hear a wolf that may have otherwise traveled into the protected area , however the effect would 15

be insignificant because wolf p opulations would be expected to continue to grow for the reasons 16

discussed in the WCMPW and in Chapter 4. 17

18

Wolf removal may occur in federally designated wilderness areas or Wildernes s Stud y Areas

. 19

The Wilderness Act (16 U.S.C. §§ 1131

- 1136) established a national preservation system to 20

protect areas “where the earth and its community life are untrammeled by man ” for the United 21

States. Wilderness areas are devoted to the public for recreational, scenic, scientific, educational, 22

conservation, and historical use. This includes the grazing of livestock where it was established 23

prior to the enactment of the law (Sept. 3, 1964). The Wilderness Act did leave management 24

authority for fish and wildlife with the State s for those species under their jurisdiction. Some 25

portions of wilderness areas in Washington have historic grazing allotments and WS may 26

conduct limited wolf removal for protecting livestock or human safety as directed by WDFW in 27

accordance with the WCMPW and coordination with the Regional Forester

. 28

29

In accordance with Forest Service Manual 2323.33 c , the Regional Forester may approve predator 30

damage ma na gement on a case

- by

- case basis to protect livestock and human health and safety in 31

designated wilderness. The Regional Forester will only approve the a ction when removing the 32

offending animal would not diminish wilderness character

. Any wolf control in Wilderness 33

Areas would be coordinated with the Regional Forester under annual WDM work plans as 34

defined in the MOU between the USFS and WS (Appendix B). Proposed WS work plans are 35

reviewed by USFS during the work planning process to ensure that areas of conflict do not ex ist. 36

Therefore, WS wolf damage management would have no negative effect on wilderness character 37

or management objectives. It would not impair the wilderness designation by Congress. 38

39

WS conforms to Revisions and Clarifications to H

- 8550

- 1 , Interim Management Policy for 40

Lands Under Wilderness Review (March 19, 200 4 memorandum (No. 2004

- 140) from BLM 41

Director to all Washington and Field Off ice Officials )

. WS f ollows BLM's Interim Management 42

Policy for Lands Under Wilderne ss Review, H

- 8550

- 1 (1995 )

, and the MOU between BLM and 43

WS. 44

45

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WS proposed activities on lands under wilderness review (WSAs) do not conflict with BLM 1

management objectives as set forth in the RMPs. In WSAs, WS work is limited to actions 2

allowed in BLM’s Interim Management Policy for Lands Under Wilderness Review (H

- 8550

- 1, 3

III. G. 5. , July 5, 1995 ), as revised (BLM 200 4 ). These documents provide , in part, that wildlife 4

damage management may be permitted in certain circumstances in order to protect domestic 5

livestock and reduce human health or safety risks. Coordination is required in order that wildlife 6

damage management activities planned in WSAs meet the non

- impairment criteria. Proposed 7

WS AWPs are presented for review by BLM during the work planning process to ensure that 8

areas of conflict do not exist. If WS did not remove the wolf, as requested by WDFW or their 9

agents c ould remove the wolf. Therefore, WS a ctions would have no effect on wilderness 10

characteristics such as size, naturalness, solitude, aesthetics, primitive or unconfined type of 11

recreation, supplemental values, and the possibility of returning the area to a natural condition as 12

stated in BLM’s Wilderness Inventory Handbook from 1978 and the Interim Management Policy 13

for L ands un der Wilderness Review

. (H

- 8550

- 1, July 5, 1995) 14

15

For the reasons discussed above, WS ’ proposed wolf damage management activities would not 16

negatively impact Wilderness o r WSAs

. 17

Additional issues not considered because they are outside the scope of this analysis 18

19

Issuance of permits to landowners to take wolves 20

21

Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 22

federally listed are managed by the USFWS. WS’ has no authority to issue permits to 23

landowners and livestock producers an d this outside the scope of any decision that WS would 24

make as a result of this EA. Actions by others to address wolf conflicts have been considered 25

u nder the cumulative impacts discussions in Chapter 4. 26

27

Desire for or opposition to a hunting season for wolves 28

29

WS has no authority to authorize or deny hunting or trapping season for wolves, and this issue is 30

outside the scope of any decision that WS would make as a result of this EA

. 31

32

Appropriateness of livestock grazing on public lands 33

34

Regulating or authorizing livestock grazing on public lands is the responsibility of the respective 35

public land management agencies , not WS

. 36

37

Appropriate population level for wolves in Washington 38

39

Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 40

federally listed are managed by the USFWS. Appropriate population levels are determined by 41

each agency, not WS, and this is outside the scope of any decision that WS would make as a 42

result of this EA. 43

44

45

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Other resources 1

2

The actions discusse d in this EA do not involve ground disturbance or construction or alteration 3

of vegetation . Therefore, the following resource values are not expected to be significantly 4

affected by the alternatives analyzed: soils, geology, minerals, water quality/quantity, flood 5

plains, wetlands, visual resources, air quality, prime and unique farmlands, aquatic resources, 6

vegetation, cultural resources or special management areas . There are no significant irreversible 7

or irretrievable commitments of resources other than a minor use of fossil fuels to operate 8

vehicles. These resources will not be analyzed further. 9

10

3.3 Evaluation Methodology 11

12

Each issue will be evaluated under each alternative and the direct, indirect

, and cumulative 13

effects w ill be disclosed as applicable. NEPA describes the elements that determine whether or 14

not an impact is “significant”. Significance is dependent upon the context and intensity of the 15

impact. The following factors will be used to evaluate the significance of the impacts in this EA 16

that relate to context and intensity (adapted from USDA (199 7, revised ) for this proposal): 17

18

Magnitude of the Impact (size, number, or relative amount of impact) (intensity)

– 19

Quantitative analysis is used where possible as it is more rigorous and is based on all known 20

sources of wolf mortality and actions provided for under the WCMPW . Magnitude may be 21

determined quanti tatively or qualitatively; 22

23

Duration and Frequency of the Impact

– 24

T emporary, seasonal impact, year round or ongoing (intensity); 25

26

Likelihood of the Impact

– 27

(intensity); 28

29

Geographic Extent

– 30

L imited to the local unit area or to the management zone (context); and 31

32

Legal Status

- 33

O f the species that may be affected ; and conformance with regulations and policies that protect 34

the resource in question (context). 35

36

The analys e s in Chapter 4 use the WCMPW and USFWS guidance/regulations as the 37

environmental baseline under which wolves are managed. The analyses do not attempt to 38

identify wolf populations or trends or whether a wolf should or should not be taken, as that is the 39

responsibility of WDFW

, USFWS , or tribes as the appropriate resource managers. The analyses 40

are limited to what effects WS may have if WS removes a wolf compared to that of WDFW, 41

USFWS, tribes, or their agents taking a wolf at the decision and request of WDFW

, USFWS , or 42

tribes

. The cumulative effect on the gray wolf population in Washington includes past, present

, 43

and reasonably foreseeable future actions of WS and others. 44

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### CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 1

2

Chapter 4 provides information needed for making informed decisions on the wolf damage 3

management objectives identified in Chapter 1. This chapter uses the four issues identified in 4

Section 3.1 as the evaluation criteria. Each issue will be analyzed for its environmental 5

consequences under each alternative. 6

7

Direct, indirect, and cumulative impacts are discussed in relationship to how WS’ actions under 8

that alternative may affect the wolf population, non

- target impacts, perspectives of human social 9

valu es and aesthetics , and effectiveness relative to if WS did not take any action . The 10

effectiveness of the alternatives is also discussed as a measure for comparison in meeting the 11

purpose and need for action. 12

13

4.1 Alternative 1

– No Action 14

15

The “No Action” Alternative is for WS to continue the existing wolf damage management 16

program as is. This is the environmental status quo, a required NEPA component, a viable 17

alternative that could be selected, and serves as a baseline for comparing the a ction alternatives 18

(CFR 1502.14[d]). Under this alternative, WS would continue its current activities conducting 19

investigations of livestock conflicts, providing the public with advice and recommendations on 20

the appropriate use of non

- lethal methods to pr otect livestock from wolf damage, and performing 21

non

- lethal control actions to reduce wolf damage. 22

23

WDFW would implement measures in the WCMPW and governing regulations and would 24

remove target wolves themselves. Tribes with management authority of wolves could 25

implement measures according to their wildlife policies. Thus, the cumulative effects of such 26

actions are the current environment under which wolves exist, and are discussed as the 27

environmental baseline, or the environmental status quo. 28

29

4.1.1 Impa ct on wolf population 30

31

Gray Wolf Population in Washington 32

33

As of March 2013, there were ten confirmed packs in Washington : seven packs in the Eastern 34

Washington, three packs in the Northern Cascades management area, and none in the South 35

Cascades & Northwest Coast management area (Figure 2). There are also indications of two 36

additional packs in the Eastern Washington management area two bordering packs (one near 37

Walla Walla and another in the north Cascade Mountains (Figure 2). A least a few solita ry 38

wolves likely occur in other scattered locations of Washington. 39

40

Continued wolf movement into Washington from adjacent states is likely given the population of 41

wolves in the state of Idaho which identified 101 documented wolf packs and an estimated 42

popu lation of 746 wolves, with additional packs overlapping along bordering states (IDFG and 43

Nez Perce Tribe 2012) . The wolf population in Washington is expected to grow as Washington 44

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wolves continue to reproduce and as wolves from other states and Canada ente r Washington 1

through natural dispersal. The Idaho portion of the NRMDPS is expected to continue to supply 2

new dispersing wolves to Washington , which will diversify the gene pool and fill in home ranges 3

that become vacant due to lethal control, natural mor tality, unintended mortalities

, or westward 4

dispersal. 5

6

T he rate of wolf dispersal into and throughout Washington cannot be predicted. The ability of 7

wolves to reach areas of habitat outside northern and eastern Washington is assumed . T here are 8

documen ted wolf packs as far west as the Cascade Mountains (Figure 2), but resident wolves or 9

packs have not yet been confirmed west of the Cascade Mountains. 10

11

As wolf activity is documented through discovery of individual wolves or wolf pack activity, 12

WDFW or USFWS will continue to radio

- collar and monitor individual s

. By monitoring and 13

observing wolves regularly, determinations regarding the habitats they select and occupy will be 14

possible. Management decisions will be evaluated for reducing conflicts whi le promoting 15

recovery

. 16

17

Wolves can occupy a variety of habitats provided adequate prey is available and they are 18

tolerated by humans (Wiles et al. 2011)

. The specific habitat chosen will be determined by prey 19

availability and human tolerance and probably will include national forests, parks, and 20

wilderness areas, designated roadless areas, and areas with low densities of open roads (Wiles et 21

al. 2011)

. Are as in the Cascade Mountains, northeastern Washington, Olympic Peninsula, and 22

Blue Mountains meet these criteria. 23

24

Direct effect on the gray wolf population 25

26

WS would have no effect on individual wolves or wolf conservation and management in 27

Washington un der the No Action alternative , other than as a provider of technical assistance and 28

select non

- lethal control to WDFW and landowners

. In this capacity, WS’s assistance would 29

help ranchers minimize wolf damage, thereby reducing the need for some lethal rem oval. Lethal 30

removal would still be required and conducted by WDFW and/ or tribes. 31

32

Cumulative effects on the gray wolf population 33

34

WS’ actions would have no negative effects on wolf populations. The wolf population in 35

Washington is expected to increase and expand throughout the state, and livestock damage is 36

also expected to increase and expand (Wiles et al. 2011). WDFW wrote that if WS was not able 37

to assist further, it WDFW would, by necessity, respond to wolf damage and would remove 38

problem wolves as defined in the WCMPW (Appendix A). Further, WDFW indicated that it 39

may remove more wolves that otherwise necessary (as compared to the Proposed Alternative) 40

since it would need to refocus its efforts away from proactive nonlethal measures. Ultimately, 41

t his alternative could hamper WDFW wo lf recovery and conservation efforts (Appendix A). 42

43

44

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4.1.2 Impacts on non

- target animals and human safety 1

2

Non

- target animals 3

4

W S would have no effect on non

- target animals or human safety under the No Action alternative. 5

6

Wolf removal actions by WDFW are expected to continue. The potentially harmful non

- lethal or 7

lethal m ethods available to WS are also available to WDFW

. 8

9

WS’s use of traps and foot snares in Washington ha s not presented any safety risks to people 10

(MIS 2012). T his conclusion was made on the national WS program by a formal risk assessment 11

of WS methods (USDA 1997

, Appendix P). It is unlikely that this risk would be higher if 12

WDFW or its agents applied these methods. 13

14

4.1.3 Social and Aesthetic Perspectives 15

16

Wildlife generally is regarded as a source of economic, recreational, and aesthetic benefits 17

(Decker and Goff 1987), and the mere knowledge that wildlife exists is a positive benefit to 18

many people. U nder this alternative, WS would not take action to remove wolves and would not 19

directly affect those with strong opinions on this aspect of wolf damage management or on 20

humaneness, nor would WS have any positive or negative effect on the ability of the pub lic to 21

potentially experience wolves in the wild. The No Action alternative would not preclude 22

WDFW and others taking actions to resolve wolf depredation, using lethal means where 23

authorized. 24

25

Humaneness 26

27

Under this alternative, wolves c ould be trapped o r shot by experienced WDFW personnel as 28

humanely as possible using the best methods available. All activities would be conducted in 29

accordance with Washington Administrative Codes and WDFW guidelines to minimize the 30

amount of time target and non

- target an imals remain in traps, and improve the likelihood that a 31

non

- target animal may be released unharmed. WS would not lethally remove or physically harm 32

any wolves including during non

- lethal harassment. 33

34

Wolves could be killed by livestock producers, where they are federally delisted, under WDFW 35

permit or when caught in the act of attacking or killing livestock (WAC 232

- 36

- 05100B) . The 36

humaneness of private individuals shooting wolves would depend on the skill of the individual 37

and their ability to ma ke a quick and efficient kill. 38

39

Some individuals would consider this alternative inhumane because they oppose all lethal 40

methods of damage management. Others will be opposed to this alternative because they object 41

to specific lethal wolf damage manageme nt methods like traps and cable restraints and perceive 42

these methods as being unjustifiably cruel and inhumane. Some individuals would prefer that 43

cage traps be used to capture wolves and would perceive this method as being more humane than 44

traps and cab le restraints. Unfortunately, the use of cage traps to capture wolves is impractical 45

and ineffective because it is extremely difficult to get a cage trap big enough for an adult wolf 46

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into remote locations, and because it is rare to capture an adult wolf i n a cage trap (USDA 2006)

. 1

Individuals with animals that have been injured, threatened

, or killed by wolves may see this 2

alternative as being acceptable because it includes necessary lethal actions to help prevent further 3

injuries to their livestock and p ets. 4

5

Finally, l ivestock owners feel that they have a right to protect their property, and may consider it 6

unacceptable that their domesticated animals be subjected to harm by wolves. 7

8

Aesthetic Effects 9

10

Aesthetics is the philosophy dealing with the nature of beauty, or the appreciation of beauty. 11

Therefore, aesthetics is truly subjective, dependent on what an observer regards as beautiful. 12

Direct benefits are derived from a user’s personal relationship or direct contact with wildlife and 13

may include either consumptive ( e.g. , using or intending to use the animal such as in hunting or 14

fishing) or non

- consumptive use ( e.g. , observing or photographing anima ls) (Decker and Goff 15

1987). Indirect benefits, or indirect exercised values, arise without a human b eing in direct 16

contact with an animal and are derived from experiences such as looking at pictures or videos of 17

wildlife, reading about wildlife, or benefiting from activities or contributions of animals such as 18

their use in research (Decker and Goff 1987) . Two forms of indirect benefits exist according to 19

Decker and Goff (1987): bequest and pure existence. Bequest benefits arise from the belief that 20

wildlife should exist for future generations to enjoy; pure existence benefits accrue from the 21

knowledge tha t the animals exist in the human environment (Decker and Goff 1987) or that they 22

contribute to the stability of natural ecosystems (Bishop 1987). 23

24

Some people directly affected by problems caused by wolves insist on the lethal removal of the 25

problem anima l(s) from the area where the conflict occurs. Others have the view that all wildlife 26

involved in conflicts should be captured and relocated to another area to alleviate the problem. 27

Individuals not directly affected by a conflict may be supportive of affec ted humans, neutral, or 28

totally opposed to any removal of wildlife from specific locations or sites. 29

30

Those who oppose removal of wildlife may do so because of emotional or spiritual ties to the 31

animals, which are similar to the bonds that may exist betwe en a human and a pet. Some may 32

totally oppose wolf damage management, especially if lethal methods are used, and want 33

management agencies to teach tolerance of wolves causing conflicts. These individuals generally 34

believe that individual animals have inher ent value and should not be killed to meet the desires 35

of man

- kind. They may also feel that individual animals have rights similar to those of humans 36

and that, if it is inappropriate to treat a human in a given manner, then it is also inappropriate to 37

trea t an animal in that manner. 38

39

Under this alternative WS would not remove wolves. WDFW w ould still remove problem 40

wolves ( Appendix A ) , as could tribal authorities. T he ability to view and aesthetically enjoy 41

wolves at a particular site could be temporarily limited when the wolves are removed. New 42

animals would most likely reoccupy the site in the future if suitable habitat exists, although the 43

length of time until new wolves arrive is variable, depending on the habitat type, time of year, 44

and population density of wolve s in nearby areas. An objective of the WCMPW is to conserve 45

wolves to the point of recovery , while managing conflicts. Given that wolves are expected to 46

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continue to expand in number and range in Washington, the current program alternative and 1

environment al status quo will not jeopardize the viability of the wolf population , thus 2

opportunities to view, hear, and aesthetically enjoy wolves will likely be available to the public 3

and grow over time as wolves reach recovery and management stages

. 4

5

4.1.4 Effec tiveness 6

7

The integrated and adaptive approach employed by WDFW , USFWS, or tribes under the 8

WCMPW could incorporate the use of lethal and non

- lethal measures to stop or reduce the 9

likelihood of wolf damage

. In assessing the effectiveness of various manag ement approaches to 10

dealing with wolf predation on livestock in the NRM area , Bangs et al. (2009) concluded that 11

while non

- lethal tools were temporarily helpful in some situations, they were generally 12

ineffective, particularly in areas that simply would ha ve too many livestock conflicts for wolf 13

packs to persist. That is, s caring wolves away from one specific location in an area with large 14

numbers of livestock everywhere else simply results in the wolf conflicts with livestock in 15

adjacent areas where focus ed non

- lethal efforts are not being employed or as ardently . Bangs et 16

al. (2009) also concluded that lethal management of problem wolves was usually effective in 17

reducing conflict because it: 1) enhanced effectiveness of non

- lethal control measures, 2) 18

in terrupted use of livestock as food by surviving wolves, 3) removed offending individuals, 4) 19

reduced wolf density in conflict areas, 5) eliminated packs where repeated livestock depredations 20

had been occurring, 6) helped to keep wolf packs out of unsuitabl e habitat, 7) made surviving 21

pack members temporarily avoid or be more wary of people and/or areas with livestock, 8) 22

reduced the pack’s overall need for food, 9) made it more difficult for the fewer remaining pack 23

members to kill larger prey like adult ca ttle or attack calves protected by cows, 10) increased the 24

detection rate of subsequent depredations because livestock carcasses were consumed more 25

slowly (so additional control could be applied more rapidly), 11) reduced compensation and 26

control costs, an d 12) moderated some of the public anger over wolf predation on livestock. 27

Mech (1995) similarly concluded that in most circumstances, lethal removal of wolves was 28

usually the only practical approach to resolving incidents of wolf predation on livestock. 29

30

Karlsson and Johansson (2009) reviewed data on livestock predation by brown bears, wolves and 31

lynx on farms in Sweden and concluded that the risk of predation greatly increased during the 32

first several weeks after an initial predation incident. They sugge sted that control efforts, 33

whether lethal or non

- lethal , would be most effective if applied during this period of time 34

following an initial depredation event. Bradley (2004) found that after partial or complete wolf 35

pack removal, depredations usually ceas ed for the remainder of the given grazing season. 36

However, the majority of packs that were partially removed (68%) depredated again within the 37

year. Where entire packs were removed, the rate of re

- colonization was high (70%) and most re

38

colonization (86% ) occurred within a year of removal of the previous pack; most packs (86%) 39

that recolonized the same area were implicated in depredations. Packs in which breeders were 40

removed were no less likely to cause depredations again within the year than packs with non

41

breeders removed. 42

43

Although non

- lethal methods are often only temporarily effective, they may sometimes offer 44

protection for a long enough period of time to protect a resource when it may be most vulnerable. 45

An example is the use of the RAG box in small calving pastures. Breck et al. (2002) reported 46

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that this frightening device, activated by the radio signal from an approaching radio

- collared 1

wolf, was effective in keeping a radio

- collared wolf pack away from several small calving 2

pastures in ce ntral Idaho for 60 days. However, this device is only useful in those cases where at 3

least one and preferably multiple wolves in the pack are radio

- collared, and it is only useful for 4

protecting relatively small areas. Fladry has also been used to deter wolves for up to 60 days 5

before the wolves habituated to it and began killing livestock again (Musiani et al. 2003). One 6

consideration in the use of these temporarily effective non

- lethal methods, is

, that if wolves will 7

eventually be lethally removed any way (after habituating to the frightening stimulus), the 8

investment of time and resources in the non

- lethal efforts may not be practical. 9

10

One of the most effective non

- lethal deterrents to wolf predation may be the on

- site presence of 11

humans who remain near the livestock and are vigilant in trying to detect the presence of wolves 12

so they can be consistently frightened away (Shivik 2004). These efforts can be more effective if 13

there are radio

- collared wolves in the area and the livestock guardian personn el make use of 14

radio

- telemetry receivers to detect the nearby presence of wolves. The costs to provide 24 / 7 15

human presence around livestock would ordinarily be cost

- prohibitive for livestock producers, 16

but in some situations, outside parties with an inter est in wolf conservation have provided such 17

assistance at no cost to livestock producers, in order to promote greater tolerance for wolves. 18

The Defenders of Wildlife have paid for such efforts in the Big Wood River drainage of central 19

Idaho during several recent summer grazing seasons, and while these efforts have not been 100% 20

effective in eliminating wolf problems, they appear to have been effective in reducing the 21

number of wolf attacks on sheep and livestock guarding dogs in this area (USDA 2010). 22

23

B angs and Shivik (2001) reported that while some non

- lethal methods may be temporarily 24

effective, many are expensive to implement and none available at the time of their report were 25

widely effective. Many non

- lethal methods of preventing livestock losses t o wolves have been 26

tried and abandoned in the United States and Europe because of lack of effectiveness. Use of 27

guard dogs alone has been tried against wolves in Minnesota with only limited success (Fritts et 28

al. 1992). Coppinger and Coppinger (1996) sho wed the dominance of wolves over livestock 29

guarding dogs in direct confrontations, and Coppinger and Coppinger (1996) and Bangs et al. 30

(1998) reported that wolves have killed livestock guarding dogs. Wolves have also been 31

translocated to other areas, but many either returned to where they were caught or became a 32

problem elsewhere (Fritts et al. 1984, 1985). Mech et al. (1996) concluded that where wolf 33

populations are large and secure, translocation has little value in wolf management. Aversive 34

conditioni ng (Gustavson and Nicolaus 1987, Shivik and Martin 2001, Shivik et al. 2003) has not 35

yet proven effective with wild wolves (Fritts et al. 1992). Electric fencing may hold some 36

promise for protecting livestock from wolves, but fences tested for coyotes hav e been extremely 37

expensive, high maintenance, and better suited for small areas (Dorrance and Bourne 1980, Nass 38

and Theade 1988, Paul and Gipson 1994), rather than range operations. 39

40

In looking at the possible role of livestock husbandry practices in red ucing wolf predation, 41

Bradley and Pletscher (2005 ) assessed multiple factors potentially related to wolf depredations 42

on cattle in fenced pastures in Montana and Idaho. They concluded there was no relationship 43

between depredations and carcass disposal met hods, calving locations, calving times, breed of 44

cattle, or the distance cattle were grazed from the forest edge. They did find that depredations 45

were more prevalent in pastures where elk were more likely to occur, where the pastures were 46

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larger in size, had more cattle, and where cattle were grazed farther from residences than 1

pastures without depredations. Mech et al. (2000) likewise concluded there were essentially no 2

differences in husbandry practices between farms in Minnesota that suffered repeated wolf 3

depredations, as compared to similar operations which experienced no depredations, and that 4

farms with cattle farther from human habitation suffered more losses. 5

6

Haight et al. (2002) and Cochrane et al. (2003) reported on a model developed to asses s three 7

different strategies for reducing wolf predation on livestock, including: 1) reactive management, 8

where wolf removal occurred soon after depredations occurred, 2) delayed reactive management, 9

where wolf removal occurred in the winter months prior t o the grazing season in areas with a 10

history of previous depredations, and 3) population

- size management, where wolves were 11

removed annually in the winter months from all areas near farms. The authors’ concluded that: 12

1) each of these approaches reduced p redation by about half compared with no action, 2) delayed 13

reactive management and population

- size management actually removed fewer wolves than 14

reactive management because wolves were removed in winter before pups were born, and 3) 15

population

- size managem ent was least expensive because repeated annual removal kept most 16

territories near farms free of wolves. The WCMPW allows lethal methods to only be used as a 17

reactive approach. 18

19

In conclusion, non

- lethal methods are used and recommended but not always su ccessful in 20

stopping or reducing damages, especially over time and must be supplemented with lethal 21

methods. WDFW’s approach is to allow for limited lethal removal of wolves after they have 22

been confirmed to have been involved in repeated livestock depred ation. WDFW has indicated 23

that it would target wolves for lethal control, similar to the proposed action, however without 24

additional assistance from WS, service to landowners may be reduced or delayed and WDFW 25

would have to redirect their personnel from co nservation and recovery focus to lethal removal, 26

thus wolf depredation on livestock may increase and overall conservation and recovery may be 27

slowed. 28

29

4.2

- Alternative 2

– Eliminate the Current Wolf Assistance Program 30

31

U nder Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 32

not provide any wolf assistance to WDFW, other public agencies, or private individuals within 33

Washington. WS would not distribute available equipment or assist landowners with the 34

impleme ntation and use of non

- lethal methods and devices. WS would not investigate wolf 35

depredation complaints to determine if the wolves are responsible for losses

. WDFW, USFWS, 36

and tribes c ould t ake the same actions as those described under the No Action alte r n ative , thus 37

nonlethal and lethal control would still occur . The cumulative effects of such actions are similar 38

to the current environment under which wolves exist, and are discussed as the environmental 39

baseline, or the environmental status quo in Secti on 4.1

. 40

41

42

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4.2.1 Impact on wolf population 1

2

Direct effect 3

4

WS would have no involvement or effect with/ on wolves. 5

6

Cumulative effects on gray wolves in Washington 7

8

The cumulative effects on wolves would be similar to that described under Section 4.1.1. 9

USFWS has responsibility for managing federally listed wolves, WDFW has responsibility for 10

managing federally delisted wolves, and trib al governments have authority on tribal lands within 11

their boundary. Ranchers and livestock producers must work directl y with WDFW and USFWS 12

when wolf/livestock conflicts occur in their areas of management. Livestock producers that see 13

wolves on their property or suspect wolves have attacked livestock are instructed to immediately 14

call WDFW

, USFWS, or county official s

. W DFW, USFWS, or tribes would implement wolf 15

damage management per appropriate regulations, as discussed in Section 2 .1

, and individual 16

wolves are expected to be removed when and wher e a need exists and in accord with the 17

requirements for removal . In additio n, producers in areas where wolves are managed by the state 18

(currently within the NRMDPS boundary), and who have been issu ed a WDFW permit or catch 19

wolves attacking their animals (WAC 232

- 36

- 05100B), may kill wolves. 20

21

Because WDFW would implement the WCMPW with or without the assistance of WS 22

( Appendix A ) , effects on the wolf population would be similar to the No Action Alternative

. 23

24

4.2.2 Impacts on non

- target animals and human safety 25

26

Non

- target animals 27

28

W S would have no effect on non

- target species or humans under th is alternative. 29

30

Human Safety 31

32

W S would have no effect on human safety under th is alternative. 33

34

Cumulative effects in Washington 35

36

Lethal methods would be used by WDFW, its agents, or tribes in the absence of any assistance 37

from WS, and thus would present no change in human safety risk from that of the current 38

environmental baseline (the No Action alternative). 39

40

In the unlikely event that wolves threatened human safety, WDFW , USFWS, and tribes c ould 41

take actions as allowed under the WCMPW , ESA, CFR, or tribal guidance

. 42

43

44

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4.2. 3 Social and Aesthetic Perspectives 1

2

Non

- lethal actions are generally preferred by members of the public. However, members of the 3

public who expe ri ence wolf threats to or losses of livestock, as well as some pet owners, feel that 4

they have a right to protect their property, and may consider it unacceptable that their 5

domesticated animals be subjected to harm by wolves by using non

- lethal methods if t hey are not 6

effective. People have bred the defensive capabilities out of many domestic animals and thus 7

may feel that they have an obligation to protect them from being killed by predators. 8

As discussed in Section 4.1.3, l ivestock producers, some rural residents, and hunters would be 9

more likely to approve of the most effective methods that will reduce wolf damages, and some 10

members of the public would prefer if wolves were removed from Washington

. 11

12

Because WDFW (Appendix A) , USFWS, or tribes c ould take necessary action to lethally remove 13

wolves under this alternative, ultimately, social perspectives would be expected to be similar to 14

the No Action Alternative. 15

16

Humaneness 17

18

The effects of this alternative would be similar to the No Action alternative because of the role of 19

WDFW in implementation of the WCMPW, which allows for nonlethal and lethal control

. 20

21

Impact of wolf removal on public aesthetic enjoyment 22

23

Under t his alternative, WS would have no effect on the ability of the public to enjoy wolve s 24

since it would have no effect on individual wolves or the wolf population. However for the 25

reasons discussed under the No Action alternative, WDFW , USFWS, or tribes c ould take any 26

necessary lethal actions and wolves would be affected similar to the No A ction alternative. 27

Thus, the ability of the public to potentially enjoy wolves in their natural habitat would be the 28

same as Alternative 1, No Action. 29

30

4.2.4 Effectiveness 31

32

Eliminating all assistance from WS would necessitate WDFW, USFWS, or tribes to direct 33

personnel away from proactive damage management and conservation and recovery efforts, 34

which would likely negatively affect wolf conservation and recovery and may result in increased 35

wolf depredation on livestock (Appendix A)

. 36

37

4.3 Alternative 3

– Proposed Action : Expand the Current Wolf Assistance Program 38

39

The Proposed Action a lternative is to assist livestock producers , tribes, WDFW, and USFWS 40

with an integrated approach of technical assistan c e, wolf damage i dentification, and nonlethal 41

and , with the exception of USFWS, lethal wolf damage management approaches under the 42

WCMPW or similar guidance

. WDFW, USFWS, and tribes would continue to implement 43

aspects of relevant wolf management (e.g., recovery and conservation) and WS would cooperate 44

to provide the assistance necessary to respond to wolf complaints and resolve depredation. This 45

alternative is almost identical to the No Action alternative except that WS c ould respond to 46

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WDFW or tribe requests to provide conservation trapping and lethal removal in accordance with 1

the WCMPW or similar guidance and assist the USFWS with conservation trapping when 2

requested and under ESA guidelines. Having WS assist WDFW or t he tribes with lethal removal 3

of wolves will allow the other agencies to focus their personnel towards conservation and 4

recovery of wolves in Washington. 5

6

This alternative is an improvement over the No Action alternative with actions allowed under the 7

WCMP W, and the environmental consequences are similar to those under Alternative 1, No 8

Action, because WS would be involved with lethal and non

- lethal wolf damage management, 9

instead of only WDFW, USFWS, or tribal personnel. The environmental consequences wou ld 10

be fewer than Alternative 2 as well, because WDFW would not be required to redirect its 11

personnel from conducting wolf conservation and recovery projects. This alternative is expected 12

to have the greatest efficacy in reducing wolf damage while benefit i ng wolf conservation and 13

recovery in WA. 14

15

4.3.1 Impa ct on wolf population 16

17

Direct effect 18

19

Effects on the wolf population under this alternative could result in a similar or lower level of 20

wolf removal as compared with Alternatives One and Two (Appendix A). Under this alternative, 21

WS may respond to WDFW or tribal requests to remove individual problem wolves under the 22

conditi ons of the WCMPW or similar guidance and assist USFWS with wolf conservation efforts 23

under ESA guidelines

. This alternative would allow WDFW, USFWS, a nd tribal personnel to 24

focus their efforts on conservation and recovery of gray wolves in Washington. It would not 25

result in more wolves removed since WDFW, USFWS, or tribes are responsible for determining 26

the number of wolves to remove and would respond if WS could not ( Appendix A )

. 27

28

Cumulative effects on gray wolves in Washington 29

30

The cumulative effect o n the gray wolf population in Washington would be similar or lower than 31

A lternative s One and Two. WDFW is already implementing the WCMPW and w oul d continue 32

to respond to wolf damage complaints in the absence of WS assistance ( Appendix A ). Without 33

WS assistance, WDFW may need to take more wolves to address wolf damage (Appendix A). 34

Because WDFW or tribes must make the decision regarding individual wolf removals of wolves 35

under their jurisdiction , and because WS would be bound to the measure s discussed in the 36

WCMPW (Wiles et al. 2011) or similar guidance , the discussion and findings under the No 37

Action Alternative, in which WDFW, USFWS, and tribes would act if WS did not, is expected to 38

be similar. 39

40

Under this alternative, WS would provide as sistance to WDFW or tribes with lethal and non

41

lethal wolf damage management and USFWS with non

- lethal management and lethal 42

management under provisions of the ESA . By providing W DFW and tribes with l ethal 43

management assistance, WDFW and tribes would be ab le to focus their personnel towards 44

programs to enhance wolf recovery and conservation. Therefore, when compared with the No 45

Action (current program) and Eliminate the Wolf Assistance Program alternatives, the proposed 46

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action alternative would result in t he greatest overall potential for wolf conservation by allowing 1

WDFW (Appendix A) , USFWS, and tribes to focus their staff time on wolf conservation and 2

recovery efforts. 3

4

Ultimately, based on WS assistance to USFWS, WDFW under the WCMPW

, WDFW ’s public 5

education and outreach, and the cautious and conservative approach to reducing wolf 6

depredation, wolves are expected to continue to expand in Washington and establish populations 7

in suitable habitat. Based on habitat connectivity and an abundanc e of wolves in other regions of 8

the NRMDPS, it is reasonable to expect that wolves will expand within the foreseeable future to 9

meet state and federal delisting criteria in Washington. 10

11

The Colville Indian Tribe opened wolf hunting to its members through 2 8 February 2013 or until 12

3 wolves are taken in each of the 3 assigned regions on the Colville Indian Reservation. This 13

action was taken after communication with state authorities and done in order to control wolf 14

populations that threaten the deer and elk tribal members rely on. WDFW takes tribal hunting 15

into account when determining wolf recovery actions so that tribal hunting will not add adverse 16

cumulative impacts to WDFW permitted wolf removals during wolf conservation and recovery 17

processes. WDFW do es not believe that this action will inhibit wolf recovery efforts in 18

Washington ( Pers. comm. Dave Ware, WDFW , July 2013 )

. 19

20

Because Washington wolf conservation and management is a relatively new issue, WS has 21

limited its proposed role in using lethal depr edation management methods to the guidance under 22

the WCMPW

, ESA

, or similar guidance from tribes. 23

24

4.3.2 Impacts on non

- target animals and human safety 25

26

Non

- target animals 27

28

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

- target animals because WDFW, its 29

agen ts, USFWS, WS, and tribes could use the same tools. N eck snares have potential to a ffect 30

non

- targets. The exposure of non

- target animals to neck snares is mitigated through consulta tion 31

with the USFWS under Section 7 of the ESA (Appendix C) . Neck snares would primarily be 32

used in the winter time when few non

- target species are present, set in wolf trails leading 33

to/away from depredation sites, and set to avoid capturing non

- target a nimals. While there may 34

be some risk to larger non

- target animals such as bear and cougar, the level of use of lethal tools 35

wou ld be so low as to render negative effects on non

- target species unlikely. WS may apply 36

other techniques more proficiently than WDFW, so effects to non

- targets could be somewhat less 37

under this alternative. WS may use neck snares when foothold traps are less effective due to 38

their mechanical nature. This tool is available to WDFW, and WS as its agent, under RCW 39

77.15.010, so it may not result in a difference in removing depredating wolves to promote wolf 40

recovery and conservation in WA. 41

42

WS Standard Operating Procedures to minimize the capture of non

- target animals is discussed in 43

Section 2. 3. 44

45

46

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Threatened and Endangered Species 1

2

During development of this EA, Wildlife Services reinitiated consultation with the USFWS 3

(February 1, 2013) , pursuant to the federal Endangered Species Act, for potential program effects 4

on bull trout ( Salvelinus confluentus ), Canada lynx ( Lynx canadensis ), Columbian white

- tailed 5

deer ( Odocoileus virginianus leucurus ), gray wolf ( Canis lupus ), grizzly bear ( Ursus arctos 6

horribilis ), pygmy rabbit ( Brachylagus idahoensis )

, and Pacific coast population of the western 7

snowy plover (Charadrius nivosus nivosus )

. WS determined “no effect” for marbled murrelet 8

( Brachyramphus marmoratus ), northern spotted owl ( Strix caurina occidentalis ), short

- tailed 9

albatross ( Phoebastria albatrus ), and woodland caribou ( Rangifer tarandus caribou ). WS 10

determined “may affect, not likely to adversely affect” for bull trout, Columbian white

- tailed 11

deer, and pygmy rabbit. WS’ final determination for western snowy plover, gray wolf, and 12

grizzly bear was “may affect, likely to adversely affect”. Base d on meetings and discussions 13

with USFWS, we expect USFWS to concur with these determinations. Actions relative to this 14

EA would have no impact on western snowy plover, may adversely affect individual federally 15

listed grays wolves (though be beneficial to the long

- term recovery of the species), and may 16

adversely affect grizzly bear if WS accidently captured a grizzly bear during wolf trapping 17

actions. In order to ensure that WS actions would not jeopardize federally listed gray wolves or 18

grizzly bear, WS would implement the conservation measures proposed in Section 2.3. 19

20

Human Safety 21

22

The methods proposed by WS would be the same as those used by WDFW under the No Action 23

alternative. WS is unaware of any impacts to public health or safety associated with agency 24

implementation of wolf damage management methods in other states. 25

26

Aerial operations would likely occur in relatively remote areas with no or very low human 27

presence on the ground. A formal risk assessment of methods used in wildlife damage 28

manag ement concluded there was very little, if any, risk to the public from WS aerial shooting 29

activities (USDA 1997, Appendix P). Other analyses of aircraft accidents by WS concluded that 30

the accident rate for WS pilots and aircraft is not significantly diffe rent from rates reported for 31

general aviation and that the risk of harming any member of the public is exceedingly low 32

(USDA 2011a, 2011b). We find no reason to believe that aerial operations used in wolf damage 33

management would present any significant ri sk to public health or safety in Washington

. 34

35

WS’ traps and snares are strategically placed to reduce the likelihood of exposure to the public. 36

A ppropriate warning signs are posted at access points to areas or properties where traps or snares 37

are set to a lert the public of their presence (WS Directive 2.450). In Idaho, where wolf removal 38

efforts are relatively high compared to what is anticipated in Washington, t here have been no 39

injuries from WS wolf damage management activities reported to WS, USFWS, Idaho Fish and 40

Game. 41

42

Humans are not likely to be exposed because of the remoteness or locations on private lands 43

where wolf removals generally occur. WS’s use of traps and snares ha s not presented any safety 44

risks to people (MIS 2012). This conclusion w as made on the national WS program by a formal 45

risk assessment of WS methods (USDA 1997

, Appendix P). Similar to the No action alternative, 46

this Alternative could provide relief from damage or threats to public health and safety for 47

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people who would have no relief from such damage or threats if non

- lethal methods were 1

ineffective or impractical. 2

3

4.3.3 Social and Aesthetic Perspectives 4

5

Humaneness 6

7

People’s perspectives on wolf damage management and on the removal of wolves under the 8

proposed action would be expected to be similar to the No Action and Non

- lethal only 9

alternative s since wolves would be removed in a similar manner and number, under the same 10

criteria ( Wiles et al. 2011 ), and for the same reasons. While WS may act as an agent to 11

landowne rs holdi ng l ethal removal permits , additional take is unlikely for the reasons discussed 12

under Section 4.3.1. 13

14

With regard to the humane treatment of wolves, the proposed action would be similar to the 15

other alternatives as far as lethal methods that WS would use (as discussed in Section 4.1.3). WS 16

would continue to provide non

- lethal technical assistance to all w ho request it. The overall 17

humaneness of the wolf management program may be enhanced under the proposed action 18

alternative because by assisting WDFW and tribes with lethal depredation response efforts, they 19

can focus their personnel towards recovery and c onservations actions. 20

21

With regard to the perspective of livestock producers and others who feel that domestic animals 22

should be protected from predation, this alternative would probably be considered more humane 23

than the other alternatives because WS may be able to respond to WDFW, USFWS (under ESA 24

guidelines) , and tribal requests for lethal removal faster and more efficiently than their agents 25

could. WS already has personnel in the field that have the expertise to identify and resolve 26

wildlife damage. By expediting response times, the potential for continued or additional wolf 27

depredation on livestock can be reduced. Enhancing agency depredation management efficiency 28

is likely to promote social tolerance of wolves in Washington, as discussed under Sectio n 4.1.3. 29

30

Aesthetic effects 31

32

Some individuals contend that there is an “existence value” placed on wolves: that a value exists 33

even though a large segment of the public will never actually see or hear a wolf. Because WS is 34

not proposing to remove all wo lves nor would WDFW authorize the killing of all wolves as a 35

manner to recover and conserve the species in Washington, there will be wolves available to 36

continue the concept of “existence value”. The ability to view and aesthetically enjoy wolves at 37

a par ticular site could be temporarily limited when a wol f is removed. New animals would most 38

likely reoccupy the site in the future if suitable habitat exists, although the length of time until 39

new wolves arrive is variable, depending on the habitat type, tim e of year, and population density 40

of wolves in nearby areas. While non

- consumptive users could be temporarily affected by 41

localized removals (especially if they recreated in areas where wolf/livestock conflicts were 42

occurring), the overall effect would be beneficial in terms of the potential for people to 43

aesthetically enjoy wolves in the wild in the long term. This alternative would provide the 44

highest level of support towards wolf conservation and recovery in Washington as identified in 45

the WMCPW (Wiles et al. 2011 , Appendix A ). Therefore, non

- consumptive users would benefit 46

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most from this alternative. Still, there are likely to be groups and individuals who would be 1

opposed to any control of wolves, regardless of the long

- term beneficial role it plays in the 2

conservation of wolves. 3

4

The likelihood of getting to see wolves is probably very low currently due to the limited numbers 5

of wolves in Washington, the remote areas they inhabit, and the lack of access to private lands 6

where wolves often occur

. The ability to directly enjoy wolves in the wild w ill probably be 7

greatest for people who have knowledge of wolf behavior and habits and make the effort to visit 8

sites with adequate habitat outside of damage management areas. 9

10

4.3.4 Effectiveness 11

12

The effectiveness of the tools and techniques proposed under this alternative to manage 13

depredation would be similar to the No Action alternative since either way, non

- lethal methods 14

are in use when they are effective, and agency lethal control would take place using the same 15

approach as provided by WCMPW. However, the proposed action would likely be more 16

efficient in resolving depredation than the No Action and Eliminate the Wolf Assistance 17

Program alternatives in alleviating additional livestock damages. WS may be more efficient in 18

responding to agency or tribal orders to remove depredating wolves as prescribed and needed to 19

prevent further losses because it has personnel in the field who already assist landowners with 20

other wildlife damage conflicts. WS personnel may be more readily available to provide 21

assistance sooner than if WDFW or tribes alone implemented lethal measures on depredating 22

wolves. As WDFW stated on 11 January 2013 , in a letter to WS ( Appendix A ), 23

24

We anticipate continued rapid growth of Washington’s wolf population and 25

without your help, we will not be able to adequately address or manage conflicts. 26

If we are unable to adequately manage conflicts, public tolerance for wolves will 27

decline and recovery efforts could be jeopardized. Whi le WDFW would still 28

provide necessary removals of wolves in the absence of additional WS assistance, 29

WDFW will not be able to respond as efficiently to potential or actual 30

depredation events and thus producers may suffer greater levels of damages. 31

Additio nally, without your program’s expert assistance, WDFW would probably 32

need to redirect personnel from overall conservation and recovery to focus on 33

responding to damages. For these reasons, without the assistance of your 34

program, overall conservation and r ecover y may be hampered

. 35

36

The same number or fewer wolves may be removed under this alternative (Appendix A)

, and 37

targeting and capture of depredating wolves would be expedited under the proposed action. 38

Because repeatedly depredating wolves may continue depredating on livestock, fewer livestock 39

losses would probably occur under this alternative. Removing a depreda ting wolf early may also 40

result in fewer pack members learning to depredate livestock, thereby reducing future 41

depredations further. 42

43

44

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4.4 Summary and Conclusions 1

2

This EA discusses approaches that WS could take to respond to requests from WDFW, USFWS, 3

a nd tribes to assist with implementing portions of the WCMPW (Wiles et al. 2011) or similar 4

guidance. The essential decision presented to WS, is not how to manage wolf damage to 5

livestock, but whether or not to assist the WDFW, USFWS, and tribes with speci fic actions 6

dictated by the WCMPW or similar guidance . This EA also evaluates the current non

- lethal only 7

alternative (No Action). The analysis in the EA shows that results of the No Action and 8

Eliminate the Wolf Assistance Program alternatives would be similar to the proposed action 9

because WDFW and tribes would continue to take necessary actions to remove repeatedly 10

depredating/problem wolves if WS did not. The primary difference s between the alternatives are 11

the probable increased efficacy of the propo sed action in reducing livestock damage and 12

enhancing the ability of WDFW and the USFWS to conserve wolves to the point of recovery, as 13

compared with the No Action and Eliminate the Wolf Assistance Program alternatives. WS has 14

no decision authority over W DFW, USFWS, or tribes in regards to calling for the remov al of 15

problem wolves . The decision to be made is to respond or not respond to their requests directing 16

when, where, and which wolves should be removed. T he methods used to capture wolves 17

include th e same methods described in Chapter 2 which WS would use in providing requested 18

assistance. The WCMPW is very specific about the criteria which call for any lethal effects on 19

wolves and if WS were to participate, it would be following such direction by WDF W or similar 20

direction from USFWS (under ESA guidelines) or tribes ( under their sovereign tribal authority )

. 21

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Oregon Department of Fish and Wildlife ( O DFW ). 2012. Oregon depredation list for WS. A

report provided to WS by Russ Morgan, Wolf Coordinator, O DFW, La Grande, Oregon

.

Packer, C., R. Holt, P. J. Hudson, K. D. Lafferty, and A. P. Dobson. 2003. Keeping the herds

healthy and alert: implications of predator control for infectious disease. Ecology Letters

6:9, 797

- 802.

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.

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Shelton, M. 2004. Predation and Livestock Production

– Pers pective and Overview. Sheep and

Goat Research Journal Volume 19. <http://www.sheepusa.o rg/index.phtml?page=site/

news_details&nav_id=4e92bbbcf5184ed243442d8fa0a7c677&nav_parent_id=601e0a31bbf

6a0e f56f1f0591aa0dc78&volume=Volume%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 di sruptive stimulus applications for

managing predation. Proceedings of the Wildli fe Damage Management Conference 9: 111

-

119.

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. Transaction s of the North American Wildlife and Natural Resource

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- 62.

Smith, R. H., D. J. Neff, and N. G. Woolsey. 1986. Pronghorn response to coyote control

- a

benef it:cost analysis. Wildlife Society Bulletin 14: 226

- 231.

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

- 2000. Wildlife

Society Bulletin 30: 23 1

- 241.

Urbigkit, C. and J. Urbigkit. 2010. A review: The use of livestock protection dogs in association

with large carnivores in the Rocky Mountains. Sheep and Goat Research Journal 25: 1

- 8.

USDA. 1997, revised. Animal damage control program, final environmental impact statement.

United States Department of Agriculture, Animal and Plant Health Inspection Service,

Animal Damage Control [Wildlife Services], Operational Support Staff, Riverdale,

Maryland, USA.

USDA, 2006. Final Environmental Assessment for the Management of Wolf Conflicts and

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Plant Health Inspection Service, Wildlife Services, Okemos

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.

USDA, 2008. Final Environmental Assessment for the Management of Wolf Conflicts and

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.

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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. Environmental Assessment, Gray Wolf Dama ge Management in Idaho for

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- WS, Boise, Idaho.

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Idaho: Final environmental impact statement. U.S. Fish and Wildlife Service, Denver,

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Distinct Population Segment of Canada Lynx. Federal Register. 68:40076

.

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Revision Of Special Regulation for t he Reintroduction o f Gray Wolves Into t he Central

Idaho a nd Yellowstone Areas. U.S. Fish and Wildlife Service, Washington D.C., USA.

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

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prairie/species/mammals/wolf/wyomingStatus09/0515 2009.html>

USFWS. 2012. Lower 48

– 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.

Washington Department of Fish and Wildlife ( WDFW ) . 2011. Final Environmental Impact

Statement (EIS) for the Wolf Conservation and Management Plan for Washington. Washington

Department of Fish and W ildlife, Olympia, Washington. 215 pp.

Wiles, G. J., H. L. Allen, and G. E. Hayes. 2011. Wolf conservation and management plan for

Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 297 pp.

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- Wildlife Services’ Gray Wolf Damage Management In Washington 66CHAPTER 5. LITERATURE CITED

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 gt 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 es 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.

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 67APPENDIX A

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 m

Pre

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- Wildlife Services’ Gray Wolf Damage Management In Washington 68APPENDIX B

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

Pre

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exchange of information and mutual program support in accordance with the following

provisions.

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.

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D. Involve APHIS

- WS in the amendment/revision of forest plans which may have an

impact on WDM activities.

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.

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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 to

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

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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 he

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

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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/or

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.

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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.

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.

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Appendix C : Summary of Public Comments

To be completed after public comments are received.

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