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, 2013
1 Table of Contents

2

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

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

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

6 Introduction ...............................................................................................................................................................1

7 1.1 Purpose ................................................................................................................................................................4

8 1.2 Need for Action ...................................................................................................................................................4

9 1.3 Scope of Analysis – Location and Actions Analyzed..........................................................................................7

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

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

12 1.6 Decision to be Made ..........................................................................................................................................11

13 1.7 Summary of Public Involvement Efforts...........................................................................................................11

14 1.8 Relationship of this EA to other Environmental Documents.............................................................................12

15 1.9 Authority and Compliance.................................................................................................................................13

16 1.9.1 Authority of Federal and State Agencies in Wolf Damage Management...................................................13

17 1.9.2 Compliance with Federal and State Laws, Policies and Executive Orders.................................................14

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

19 2.1 Alternative 1 - No Action ..................................................................................................................................18

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

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

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

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

24 Monitoring...........................................................................................................................................................26

25 2.2 Alternative 2 – Eliminate the Current Wolf Assistance Program......................................................................26

26 2.3 Alternative 3 – Proposed Action – Expand the Current Wolf Assistance Program...........................................27

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

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

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

30 Monitoring...........................................................................................................................................................37

31 2.4 Summary of Actions allowed by Alternative.....................................................................................................37

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

33 3.1 Issues Driving the Analysis...............................................................................................................................40

34 3.2 Issues Not Analyzed in Detail, with Rationale ..................................................................................................40

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

36 3.3 Evaluation Methodology ...................................................................................................................................44

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

38 4.1 Alternative 1 – No Action..................................................................................................................................45

39 4.1.1 Impact on wolf population..........................................................................................................................45

40 4.1.2 Impacts on non-target animals and human safety.......................................................................................47

41 4.1.3 Social and Aesthetic Perspectives...............................................................................................................47

42 4.1.4 Effectiveness...............................................................................................................................................49

43 4.2 - Alternative 2 – Eliminate the Current Wolf Assistance Program....................................................................51

44 4.2.1 Impact on wolf population..........................................................................................................................52

45 4.2.2 Impacts on non-target animals and human safety.......................................................................................52

46 4.2.3 Social and Aesthetic Perspectives...............................................................................................................53

47 4.2.4 Effectiveness...............................................................................................................................................53

48 4.3 Alternative 3 – Proposed Action: Expand the Current Wolf Assistance Program.............................................53

49 4.3.1 Impact on wolf population..........................................................................................................................54

50 4.3.2 Impacts on non-target animals and human safety.......................................................................................55

51 4.3.3 Social and Aesthetic Perspectives...............................................................................................................57

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington i
1 4.3.4 Effectiveness...............................................................................................................................................58

2 4.4 Summary and Conclusions ................................................................................................................................59

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

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

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

6 Appendix C: Summary of Public Comments..............................................................................................................77

7

8

9

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington ii
1 List of Acronyms and Abbreviations 

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

3 AVMA American Veterinary Medical Association

4 BLM Bureau of Land Management (USDI agency)

5 CEQ President’s Council on Environmental Quality

6 CFR Code of Federal Regulations

7 EA Environmental Assessment

8 EIS Environmental Impact Statement

9 EJ Environmental Justice

10 EO Executive Order

11 ESA Endangered species Act

12 FR Federal Register

13 MIS Management Information System

14 MOU Memorandum of Understanding

15 NEPA National Environmental Policy Act

16 NHPA National Historic Preservation Act

17 NRMDPS Northern Rocky Mountain Distinct Population Segment

18 RAG Radio Activated Guard

19 RCW Revised Code of Washington

20 T&E Threatened and Endangered 

21 USC United States Code

22 USDA United States Department of Agriculture

23 USDI United States Department of the Interior

24 USFS United States Forest Service (USDA agency)

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

26 WAC Washington Administrative Code

27 WCMPW Wolf Conservation and Management Plan for Washington

28 WDFW Washington Department of Fish and Wildlife

29 WDM Wildlife Damage Management

30 WS Wildlife Services (USDA-APHIS program)

31

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington iii
1 EXECUTIVE SUMMARY

2

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

19

20 Legal status of wolves in Washington

21

22 The most pertinent and recent 

23 regulatory action was a 5 May 2011 

24 federal delisting of wolves from the 

25 federal Endangered Species Act 

26 (ESA) in eastern Washington, which 

27 will not be subject to judicial review 

28 (76 FR 25590; 5 May 2011, as 

29 mandated by Public Law 112–10). 

30 Under this rule, wolves were 

31 federally delisted in Washington east 

32 of Highway 97 from the British 

33 Columbia border south to Monse, 

34 Highway 17 from Monse south to 

35 Mesa, and Highway 395 from Mesa 

36 south to the Oregon border, but 

37 remained federally listed west of 

38 these highways (Figure 1) (74 FR 

39 15123; April 2, 2009). This boundary

40 falls within WDFW’s eastern wolf 

41 management zone.

42

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

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

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

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

Wildlife Service as the Northern Rocky Mountain distinct 

population segment of gray wolves.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington iv
1 tribal authority. Gray wolves are currently classified as endangered under Washington state law

2 throughout the state (Washington Administrative Code 232-12-297). Based on the expected re3 establishment of wolves in Washington, WDFW developed a Final Recommended Wolf 

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

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

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

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

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

9 and ungulates” (Wiles et al. 2011).

10

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

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

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

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

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

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

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

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

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

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

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

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

23

24 Need for Action

25

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

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

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

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

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

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

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

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

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

35

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

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

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

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

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

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

42 capture or removal. 

43

44

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington v
1 Actions Analyzed

2

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

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

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

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

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

8 variety of non-lethal damage management assistance to livestock producers, research (e.g., live9 capture, monitoring), and public education. At the request and direction of WDFW, WS may 

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

11 depredations.

12

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

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

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

safety or for euthanasia in accordance with ESA guidelines1 16 and Code of Federal Regulations 

(CFR)2 17 . On tribal lands, WS may assist tribal governments with all forms of wolf management. 

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

19

20 Alternatives

21

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

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

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

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

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

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

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

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

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

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

32 of WDFW/USFWS overall conservation and recovery.

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

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

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

C.F.R. §§ 17.21(c)(2), 17.21(c)(3), and 17.31(a) (1993).

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington vi

 
1 Environmental Consequences

2

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

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

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

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

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

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

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

10 few negative effects on other animals and humans.

11

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

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

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

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

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

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

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

19

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

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

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

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

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

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

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

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

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

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

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

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

32 (Appendix A, letter from WDFW). 

33

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

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

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

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

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

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

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

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

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

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington vii
CHAPTER 1. PURPOSE AND NEED FOR ACTION

1 CHAPTER 1. PURPOSE AND NEED FOR ACTION

2

3 Introduction

4

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

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

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

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

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

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

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

12 resulted in resident breeding population.

13

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

15 232-12-014) and under federal law [Endangered Species Act (ESA)] in the western two-thirds of 

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

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

18

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

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

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

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

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

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

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

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

27

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

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

30 232-12-297).

31

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

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

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

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

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

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

38

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

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

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

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

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

44 wolves occur in northeastern Washington.

45

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

1

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

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

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

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

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

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

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

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

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

11 assistance in an efficient and effective manner.

12

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

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

boundary3 15 (NRMDPS) (Figure 1). Gray wolves throughout Washington are protected under 

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

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

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

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

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

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

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

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

Figure 2. Map of known wolf home ranges in Washington as of 15 November 2013.

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

 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

1 lethal actions for federally listed wolves. 

2

3 Recent Legal Status Changes

4

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

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

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

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

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

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

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

12 included portions of Idaho, Wyoming, and Montana.

13

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

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

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

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

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

19 all wolves in Washington were federally-listed as endangered.

20

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

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

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

24 25590). That act of Congress changed the legal status of wolves in the eastern third of 

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

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

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

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

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

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

31 the date of publication.

32

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

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

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

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

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

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

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

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

41 sovereign tribal lands under the WCMPW or similar guidance. 

42

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

1 1.1 Purpose

2

3 Purpose of the Proposal

4

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

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

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

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

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

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

11 WCMPW or similar guidance.

12

13 1.2 Need for Action

14

15 Direct predation on livestock

16

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

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

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

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

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

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

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

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

25 safety. 

26

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

28 2007. More recent wolf attacks on livestock were confirmed July through September 2012, in 

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

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

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

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

33

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

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

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

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

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

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

40 capture or removal.

41

42 Confirmed losses underestimate probable losses

43

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 4
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

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

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

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

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

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

confirmed wolf kills, he received a compensation payment in the amount of $8004 7 but he 

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

9 direct losses which totaled $7,400.

10

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

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

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

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

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

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

17 suggested that wolf-caused mortalities were difficult to detect.

18

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

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

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

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

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

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

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

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

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

28

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

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

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

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

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

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

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

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

37 disappeared.

38

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

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

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

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

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

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

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

 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

2 Shivik 2001).

3

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

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

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

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

8

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

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

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

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

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

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

15

16 Indirect depredation effects on livestock

17

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

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

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

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

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

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

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

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

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

27 acreage.

28

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

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

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

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

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

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

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

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

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

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

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

40 wolf depredation and threats can have on individual livestock operations.

41

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

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

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 6
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

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

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

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

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

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

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

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

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

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

11

12 Wolf predation on dogs

13

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

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

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

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

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

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

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

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

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

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

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

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

26 (ODFW 2010).

27

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

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

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

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

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

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

34

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

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

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

38 conflicts could be expected.

39 1.3 Scope of Analysis – Location and Actions Analyzed 

40

41 Location

42

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 7
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

2 sovereign tribal governments wherever potential or confirmed repeated depredations arise. 

3

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

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

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

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

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

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

10

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

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

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

14

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

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

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

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

19

20 Site Specificity

21

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

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

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

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

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

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

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

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

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

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

32 to site-specific analysis.

33

34 Actions Analyzed

35

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

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

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

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

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

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

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

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

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 8
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

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

3

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

5 Notwithstanding the provisions of WAC 232-36-051:

6

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

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

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

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

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

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

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

14 within twenty-four hours.

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

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

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

18 collection or incident investigation.

19

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

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

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

23 under RCW 77.15.120.

24

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

26 removals under RCW 77.12.240.

27

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

29 wolves under WDFW permit conditions for livestock producers or permittees. The specific non30 lethal and lethal measures to reduce wolf conflicts are discussed in detail in the Sections 2.1 and 

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

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

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

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

35 with the WCMPW or similar guidance. 

36

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

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

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

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

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

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

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

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 9
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

2 guidance of the ESA.

3

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

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

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

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

8 wildlife management agencies.

9

10 1.4 WDFW Wolf Management Goals

11

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

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

14 or similar implementation guidelines outlined in the WCMPW.

15

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

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

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

19 livestock.

20

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

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

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

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

25

26 The goals of the WCMPW are to:

27

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

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

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

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

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

33 sustainable wolf population.

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

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

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

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

38

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

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

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

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

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

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

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

46

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 10
CHAPTER 1. PURPOSE AND NEED FOR ACTION

1 1.5 Period for which this EA Remains Valid 

2

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

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

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

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

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

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

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

10 1.2, would be expected to increase over time as Washington’s wolf populations grow and 

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

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

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

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

15 eventual State delisting.

16

17 1.6 Decision to be Made

18

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

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

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

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

23 during preparation of the EA.

24

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

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

27 WCMPW as well as assisting USFWS and sovereign tribal governments?

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

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

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

31 require an EIS?

32

33 1.7 Summary of Public Involvement Efforts 

34

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

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

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

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

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

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

41 reviews of the draft EA.

42

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

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

45 the Olympian on December 17, 2013, and by posting the pre-decisional EA on

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

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

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

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

4 are received.

5

6 1.8 Relationship of this EA to other Environmental Documents 

7

8 Final Rule to Delist NRMDPS

9

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

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

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

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

USFWS 2 April 2009, Final Rule (74 FR 15123) http://www.regulations.gov 5 14

15

16 2011 Wolf Conservation and Management Plan for Washington.

17

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

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

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

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

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

23

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

25 Washington.

26

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

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

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

30

31 Wildlife Services Programmatic Final Environmental Impact Statement

32

33 WS issued a Final EIS on the national APHIS-WS program and Record of Decision published in 

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

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

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 our 2009 delisting rule 

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

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

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

judicial review. 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 12

 
CHAPTER 1. PURPOSE AND NEED FOR ACTION

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

2

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

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

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

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

7 incorporated by reference in this EA.

8

9 1.9 Authority and Compliance 

10

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

12 in compliance with applicable federal, state and local laws.

13

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

15

16 APHIS-Wildlife Services

17

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

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

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

21 22, 1987 (101 Stat. 1329-331, 7 U.S.C. 426c). WS recognizes that wildlife is an important 

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

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

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

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

26 another.

27

28 United States Bureau of Land Management (BLM)

29

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

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

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

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

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

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

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

37 coordinate with them when requested by a grazing leasee.

38

39 United States Fish and Wildlife Service (USFWS)

40

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

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

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

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

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

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

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 13
CHAPTER 1. PURPOSE AND NEED FOR ACTION

1 United States Forest Service (USFS)

2

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

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

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

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

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

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

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

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

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

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

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

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

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

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

17 Plans.

18

19 Washington Department of Fish and Wildlife

20

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

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

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

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

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

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

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

28

29 1.9.2 Compliance with Federal and State Laws, Policies and Executive Orders

30

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

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

33

34 Bureau of Land Management

35

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

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

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

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

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

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

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

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

44 WS NEPA processes.

45

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

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

2 Populations and Low-Income Populations

3

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

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

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

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

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

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

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

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

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

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

14

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

16

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

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

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

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

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

22 not increase environmental health or safety risks to children.

23

24 Federal Endangered Species Act

25

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

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

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

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

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

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

32 listed species.

33

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

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

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

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

38 species.”

39

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

41

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

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

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

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

46 Hunting Act but has given implementation to the states. WDFW or its agent is authorized to 

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

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

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

3

4 National Environmental Policy Act

5

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

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

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

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

10 1508), and USDA APHIS NEPA Implementing Regulations (7 CFR Part 372).

11

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

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

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

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

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

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

18

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

20

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

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

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

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

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

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

27 resources.

28

29 Tribal Authorities

30

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

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

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

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

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

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

37 objectives, within the framework of applicable laws.

38

39 U.S. Fish and Wildlife Service

40

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

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

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

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

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

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

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

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

3

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

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

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

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

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

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

10

11 U.S. Forest Service

12

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

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

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

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

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

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

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

20

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

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

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

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

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

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

27

28 Washington Endangered Species Act

29

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

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

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

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

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

35 threats.

36

37 WDFW - Mandate (RCW 77.04.012)

38

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

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

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

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

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

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

45 impair the supply of these resources.

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

1 CHAPTER 2. DESCRIPTION OF ALTERNATIVES

2

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

18 conservation and recovery efforts.

19

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

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

22 WDFW, USFWS, or tribes.

23

24 2.1 Alternative 1 - No Action 

25

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

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

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

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

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

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

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

33

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

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

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

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

38 WDFW/USFWS and/or other appropriate agencies.

39

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

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

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

43

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

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

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

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

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

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

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

7 WDFW.

8

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

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

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

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

13

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

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

16

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

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

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

20 relocation, and lethal removal):

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

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

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

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

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

26 bodily harm.

27 o Non-lethal injurious harassment: This form of harassment involves striking wolves with non28 lethal projectiles, such as rubber bullets specifically designed and approved for use on 

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

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

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

32 not apply injurious harassment toward wolves under this alternative.

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

34 remove the animal from a conflict situation. This activity would be evaluated on a case35 specific basis, but would especially be considered during endangered and threatened status. 

36 WS would not capture or relocate wolves under this alternative.

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

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

39 portion of the state.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

23 WAC 232-36-051, it is unlawful to kill state endangered species causing damage to 

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

25

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

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

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

29 WAC 232-36-050(3)(a)). It is important to understand that wolves passing near, watching, or 

30 otherwise behaving in a non-threatening way near humans should not necessarily be considered 

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

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

33

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

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

36 activities.

37

38 • Several research projects are identified as necessary for future success of long-term wolf 

39 conservation and management. Monitoring and radio-collaring wolves are listed as critical 

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

41

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

43 Washington as wolves become reestablished. Resolving wolf-livestock conflicts will require 

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

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

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

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

48 for reestablishing the species in the state.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 20
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

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

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

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

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

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

6 unsuccessful attempts to solve wolf-livestock conflict with non-lethal methods.

7

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

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

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

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

12 approach. Lethal control will be used only as needed after case-specific evaluations are made, with 

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

14 removal under this alternative.

15

16 Currently, state laws RCW 77.36 and WAC 232-36 allow owners of commercial livestock (cattle, 

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

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

19 a state compensation program for documented confirmed and probable wolf-killed livestock in order 

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

21 listed. Public support for a state-funded wolf compensation program was expressed in the comments 

22 received during public meetings in 2007 and 2009 and the plan’s public review period in 2009-2010. 

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

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

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

26

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

28 on the use of non-lethal methods, could investigate wolf damage incidents and report results to 

29 WDFW, and could conduct select nonlethal harassment. WDFW makes the final determinations.

30

31 Non-lethal Methods Available to WS, WDFW, USFWS, Tribes, and the Public

32

33 Some wolf damage management methods are available for anyone to use. These consist of non34 lethal preventive methods such as cultural practices (e.g., possible changes in livestock 

35 management) and localized habitat modification (e.g., clearing brush, improving fencing, etc.) on 

36 private property. Cultural practices and other management techniques are implemented by the 

37 resource owners/managers. Livestock producers and resource owners/managers are encouraged 

38 to use these methods, based on the level of risk, need and professional judgment on their 

39 effectiveness and practicality. WS’, WDFW’s, or USFWS’ involvement in the use of these 

40 methods is usually limited to providing technical assistance.

41

42 Livestock Management Practices are implemented to prevent or reduce wolf damage and may 

43 include approaches such as: 1) maintaining healthy, well-fed animals, 2) properly disposing of 

44 livestock carcasses (i.e., removal, burying, liming, or burning), 3) conducting calving or lambing 

45 operations in close proximity to the ranch headquarters when practical, 4) penning vulnerable 

46 livestock at night where practical, 5) monitoring livestock on a regular basis to detect any 

47 disease, natural mortality, or predation, 6) keeping livestock away from areas of historic wolf 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 21
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 activity, and 7) incorporating other non-lethal methods. Property owners and land managers 

2 could implement these management practices or request the assistance of other agencies or 

3 private organizations to implement them, or take no action.

4

5 Exclusion with some type of fence or other barrier may be used to prevent or limit access by 

6 predators to livestock pastures, calving or lambing areas, or livestock confinement areas. Where 

7 practical and cost effective, sheep, calves, or other vulnerable livestock may be penned near 

8 ranch buildings at night.

9

10 Fladry is a form of barrier and wolf deterrent involving red flags measuring approximately 3 x 

11 18 inches, strung about 20 inches apart, hanging from a thin rope or cord suspended about 30 

12 inches above the ground. Fladry is installed around pastures or other areas where livestock are 

13 confined to discourage wolf access. Part of the repellency provided by fladry is probably related 

14 to the frequent human visitation required to ensure that the flags remain freely suspended and 

15 that the line is properly maintained. Like many other frightening devices, wolves eventually 

16 habituate to this deterrent, but field trials in Idaho have shown that fladry may provide deterrence 

17 for as long as 60 days (Musiani et al. 2003). Davidson-Nelson and Gehring (2010) reported that 

18 if maintained, fladry can exclude wolves from livestock for up to 75 days; however Shivik et al. 

19 (2003) found that fladry did not effectively protect bait sites from scavengers, including wolves.

20

21 Turbo-Fladry is very similar to regular fladry with the exception that the cord is substituted 

22 with electrified wire attached to a standard livestock electric fence generator. As wolves 

23 habituate to the fladry line and try to cross under it, the negative stimulus they receive after 

24 getting shocked by the electrified barrier can increase the amount of time the barrier may remain 

25 effective.

26

27 Livestock guarding animals such as large, aggressive breeds of guarding dogs (e.g., Great 

28 Pyrenees, Akbash, etc.) have been used with some success to protect livestock from wolves, but 

29 multiple guard dogs work better than just one or two guard dogs (Bangs et al. 2005, Urbigkit and 

30 Urbigkit 2010). Even with 3 or more dogs present, wolves occasionally kill or severely injure 

31 livestock guarding dogs. Livestock guarding dogs are generally not killed as prey but because of 

32 interspecies aggression (Bangs et al. 2005). Other types of livestock guarding animals, such as 

33 llamas, which have been shown in some circumstances to be effective in protecting sheep from 

34 coyotes, are not as effective in deterring wolves. Wolves probably view llamas as prey, and 

35 multiple instances of wolves killing and feeding on llamas have been documented in the NRM 

36 area (USFWS et al. 2003, 2008, 2009, and 2010).

37

38 Guarding and hazing involves using human presence to guard an area and then using 

39 pyrotechnics or other frightening devices to frighten wolves from the site if/when they arrive. 

40 Hazing can be used as an aversive technique, but requires that the technique be used consistently 

41 whenever the animal attempts to prey on the protected resource so they do not identify 

42 conditions when they can obtain prey without receiving a negative experience (Shivik 2004). If 

43 there are any radio-collared wolves in a pack which may pose a threat to livestock, non-lethal

44 hazing efforts can be enhanced if the livestock producer or other personnel make use of a radio 

45 receiver to determine when wolves are near or approaching the livestock (Bangs et al. 2006). 

46 This requires diligent and persistent monitoring, but can make hazing much more effective.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 22
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 Frightening devices are methods that usually involve lights, sound and/or motion devices 

2 designed to deter wolves from a certain area. Strobes and flashing lights, propane exploders, 

3 sirens, and various combinations of these devices have all been used in attempts to reduce 

4 livestock losses, with wide-ranging degrees of effectiveness (Linhart 1984, Andelt 1987). 

5 Animal habituation (becoming accustomed) to the stimulus is one of the primary limiting factors 

6 for repellents. Essentially, anything new or different is likely to elicit avoidance behavior by 

7 canids, but this effectiveness disappears over time. Moving the devices intermittently and 

8 randomly as well as alternating the stimuli (e.g., a different type of noise or light) may extend the 

9 effective period of the system (Shivik and Martin 2001). The period of efficacy may also be 

10 extended by using systems which are motion-activated or only activated when a wolf wearing a 

11 transmitter collar comes into close proximity to the protected site. The RAG box is one such 

12 frightening device that employs this approach, and RAG boxes have been field-tested in Idaho 

13 with some success (Breck et al. 2002). Use of the RAG box in Idaho has been most effective in 

14 protecting livestock in small (≤60 acre), fenced-in areas.

15

16 Non-lethal Methods Available to WDFW, USFWS, and Tribes, but not WS

17

18 Some non-lethal methods, research projects, and population monitoring efforts involve capture 

19 and handling wolves which may not be conducted by the general public. Methods that require 

20 capture and handling of wolves under state authority would only be conducted by WDFW

21 personnel or agencies permitted by the WDFW. Sovereign tribal governments could act under 

22 their own authority on sovereign tribal lands. 

23

24 Foot-hold traps can be effectively used to live capture wolves, and are an extremely important 

25 tool in wolf damage management. When wolves are trapped they are ordinarily physically 

26 restrained or chemically immobilized, radio-collared, and released on site, or euthanized on site. 

27 Effective trap placement, pan-tension devices and the selection and placement of appropriate 

28 lures and baits by trained personnel contribute to the foot-hold traps’ selectivity. Traps may also 

29 be modified with small protrusions or “nubs” on the jaws to reduce the likelihood of the wolf’s 

30 foot moving back and forth in the jaws, thereby reducing the potential for trap-related injury. 

31 Washington State has a trap check rule in effect requiring that all foothold traps be checked 

32 every 24 hours.

33

34 Disadvantages of traps include the difficulty of keeping them operational during rain, snow or 

35 freezing weather, and the fact that they cannot be 100% selective. Although pan-tension devices 

36 are effective in reducing the likelihood of unintentional capture of non-target species smaller 

37 than wolves (e.g., red fox, coyote), they cannot preclude the occasional capture of larger non38 target species such as cougars or black bears. They do, however allow for the option of releasing 

39 non-target animals which may infrequently be captured. 

40

41 Foot snares are devices consisting of a cable loop and a locking device that captures an animal 

42 around its foot or lower leg. The cable may be activated around the lower leg with a spring43 powered throw-arm (Aldrich-type) or trap-type (Belisle) device. The foot snare can be modified 

44 with a stop on the cable to restrict the closure of the loop. Careful snare placement, pan-tension 

45 devices and the selection and placement of appropriate lures and baits by trained personnel 

46 contribute to the selectivity of this device. As with foot-hold traps, when foot snares are used as 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 23
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 a live-capture device, wolves would ordinarily either be radio-collared and released on site, or 

2 euthanized. Foot snares are more often used for capture of cougars and black bears than for 

3 wolves. Washington State has a trap check rule in effect requiring that all foot snares be checked 

4 every 24 hours.

5

6 Drug delivery tools are capture tools that utilize a dart or syringe filled with an immobilization 

7 drug, dispensed from a specially-designed device. These devices include hand or poll syringes, 

8 blow guns, and compressed gas or gun-powder charged systems. They would often be used on 

9 wolves when conducting live-capture operations from a helicopter. Once immobilized, the 

10 animal may be handled safely and processed for research or monitoring purposes. Use of drug 

11 delivery tools would have no effect on non-target species because positive target species 

12 identification is made before animals are darted. 

13

14 Neck Snares can be used to kill, or to live-capture animals with a cable loop around the neck 

15 and the use of a “stop” to prevent full closure of the loop. Improved methods for use are being 

16 developed for live-trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 

17 are ordinarily not as affected by rain, snow, and freezing weather as foot-hold traps are. These 

18 devices offer a degree of selectivity based on the size of the cable loop and the height of the loop 

19 above ground level. They also offer a viable live-capture alternative to foot-hold traps during the 

20 winter months, when freezing temperatures combined with restricted blood circulation could 

21 result in damage to the wolf’s foot.

22

23 Non-lethal Methods which may Require Special Authorization from WDFW, USFWS,

24 and Tribes

25

26 These methods are not available to WS under this alternative (Alternative 1, NO Action). Some 

27 animal behavior modification systems involve capturing and fitting wolves with radio28 transmitting collars to deliver or trigger repellent stimuli (i.e., aversive conditioning). Other 

29 systems sometimes referred to as “less than lethal munitions,” involve shooting wolves with 

30 projectiles such as rubber bullets or bean bag rounds. These techniques involve intentionally 

31 using painful stimuli to modify wolf behavior and WDFW and the USFWS may require permits 

32 or other authorizations to use these methods and any other experimental wolf damage 

33 management techniques. Methods that require capture and handling of wolves would be 

34 conducted only by personnel from WDFW, USFWS, or tribes, and / or personnel authorized by 

35 either of these entities.

36

37 Aversive Stimuli are stimuli that cause discomfort, pain and/or an otherwise negative experience 

38 paired with specific behaviors to achieve conditioning against these behaviors. One example 

39 would be using something like a dog training shock collar that is activated when wolves come 

40 into close proximity to a protected area such as livestock pens (Shivik et al. 2003, Schultz et al. 

41 2005).

42

43 Non-lethal Projectile use involves guarding an area and then using rubber bullets, bean bag 

44 rounds or other non-lethal projectiles to prevent a predation event. They can be used as an 

45 aversive technique, but require that the projectiles be used consistently whenever the predator 

46 attempts to prey on the protected resource, so it is less likely to identify conditions when it can 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 24
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 obtain prey without receiving a negative experience (Shivik 2004). Methods which require 

2 around-the-clock presence of a person to guard the resource are most efficiently used when there 

3 are radio-collared wolves involved and the landowner/resource manager assists with the 

4 implementation. WDFW authorizes the use of these methods.

5

6 For additional discussion of the advantages and disadvantages of various non-lethal and lethal 

7 wolf damage management methods used in the NRM, see Bangs et al. (2006) 

8 (http://www.aphis.usda.gov/wildlife_damage/nwrc/publications/06pubs/shivik067.pdf).

9

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

11

12 These methods are specifically designed to lethally remove wolves in certain situations to 

13 stabilize, reduce, or eliminate damage. The amount of removal necessary to achieve a reduction 

14 in wolf damage varies according to the effectiveness of other damage management strategies, the 

15 damage situation, and the level and likelihood of continued depredations. There would be no 

16 lethal wolf damage management techniques available to WS under Alternative 1, but the use of 

17 foothold traps and snares, as described above, followed by euthanasia, typically by gunshot to 

18 the brain, as recommended by the American Veterinary Medical Association (AVMA 2013, 

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

20 lethal methods used under Alternative 1 would include shooting from the ground as well as from 

21 fixed-wing aircraft or helicopters.

22

23 Shooting from the ground is highly selective for the target species, and may be employed in 

24 conjunction with the use of auditory attractants (e.g., sounds of prey animals in distress or 

25 imitations of wolf vocalizations). Removal of one or two specific animals by shooting in the 

26 problem area can sometimes provide immediate relief from a predation problem. Shooting is 

27 often tried as one of the first lethal management options because it offers the potential of solving 

28 a problem more quickly and selectively than some other techniques, but it requires visually 

29 sighting the wolf within effective shooting distance. Shooting may sometimes be one of the only 

30 management options available if other factors preclude the setting of equipment (i.e., traps or 

31 snares).

32

33 Aerial Shooting typically involves visually locating suspected depredating individuals or packs 

34 from either a small single-engine fixed-wing aircraft or a helicopter, and shooting them from the 

35 aircraft. Depredation problems can sometimes be resolved very quickly and effectively through 

36 aerial shooting (e.g., by starting the aerial operation in the vicinity of a recent wolf kill and 

37 catching the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) 

38 rated aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of 

39 adverse environmental impacts. Smith et al. (1986) cited cost-effectiveness and efficacy as 

40 benefits of aerial shooting.

41

42 Good visibility is required for effective and safe aerial shooting operations, and relatively clear 

43 and stable weather conditions are necessary. Summer conditions limit the effectiveness of aerial 

44 shooting because the increased vegetative cover makes finding the animals more difficult, and 

45 the higher ambient air temperatures reduce air density, which affects low-level flight safety.

46 Aerial shooting is one of the most effective wolf damage management tools available.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 25
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 Sodium Pentobarbital (Beuthanasia®-D) is registered for euthanasia of dogs, but may legally 

2 be used for other animals if the animal is not intended for human consumption. Barbiturates 

3 depress the central nervous system in descending order, beginning with the cerebral cortex, with 

4 unconsciousness progressing to death. The primary advantage of barbiturates is the speed of 

5 action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the 

6 animal (AVMA 2013). This method of euthanasia would likely only be used in the rare 

7 circumstance where an already sedated wolf was determined to have health or injury issues such 

8 that it would be most appropriate to euthanize the animal.

9

10 Monitoring

11

12 WS provides information on wolf sightings, identification of wolf activity (tracks or scat), 

13 depredation investigations, telemetry searches, or any other monitoring activities. Wildlife 

14 Services monitors its program activities using a national software program, Management 

15 Information System (MIS), which compiles data on harassment locations, damages, methods 

16 used, and other information. Information from MIS can then be provided to cooperating 

17 agencies, used in wildlife management decisions and environmental analyses, and is available to 

18 the public.

19

20 2.2 Alternative 2 – Eliminate the Current Wolf Assistance Program

21

22 Under Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 

23 not provide any wolf assistance to WDFW, USFWS, other public agencies, tribes, or private 

24 individuals within Washington. WS would not distribute available equipment or assist 

25 landowners with the implementation and use of non-lethal methods and devices. WS would not

26 investigate wolf depredation complaints to determine if the wolves are responsible for losses. 

27 WDFW would make the final determinations for investigations under their jurisdiction. WS 

28 would not assist WDFW, USFWS, or tribes with capturing wolves for radio-collaring for 

29 monitoring purposes and/or to enhance effectiveness of non-lethal deterrents such as the RAG

30 devices. 

31

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

33 including actions that could be taken to protect livestock from wolf depredation. Alternative 2 

34 encompasses all the primary components of the WCMPW and all actions and components listed 

35 in Alternative 1, but removes WS as an assisting agency to WDFW, USFWS, and tribes. While 

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

37 actually participate in any wolf-related actions under this alternative. WDFW, or its agents,

38 would have to redirect personnel from conducting wolf research, outreach, and recovery projects

39 to conducting wolf control and removal. WS would not be able to guarantee any mitigation 

40 measures against the accidental impact to target and non-target wildlife, public safety, or 

41 personnel safety during wolf control activities conducted by others.

42

43

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 26
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 2.3 Alternative 3 – Proposed Action – Expand the Current Wolf Assistance Program

2

3 This alternative would allow WS to use non-lethal methods, capture wolves for monitoring or 

4 translocation needs, and respond to requests by WDFW or tribes to lethally remove non-federally 

5 listed depredating wolves, and with the addition of USFWS, wolves jeopardizing public safety as 

6 outlined in the WCMPW or similar guidance (e.g., ESA and CFR). Wolves could be removed 

7 after a request from WDFW or tribes based on confirmed livestock depredation and after 

8 unsuccessful attempts using non-lethal methods had been documented. The proposed action 

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

10 activities. 

11

12 The role of WS in this program would be direct: WS would conduct a fully integrated approach 

13 to wolf damage management, as requested by WDFW, USFWS, or tribes under the guidance of 

14 the WCMPW or similar guidance. WDFW would maintain responsibility for making the final 

15 determinations on removal of federally delisted wolves, USFWS would retain management of 

16 federally listed wolves, and tribes would maintain management of wolves on tribal lands. WS 

17 wolf damage management on tribal lands would mirror procedures and restrictions on non-tribal 

18 lands, with the exception that tribal wildlife managers or WS may confirm wolf damages.

19

20 As per WS policy, it would only provide direct wolf damage management on properties after 

21 Agreement for Control or other work authorization documents have been completed. On federal 

22 public lands, planned activities must be included in work plans developed in coordination with 

23 each National Forest or BLM Resource Area, or in emergency, unplanned situations, in 

24 consultation with the respective USFS or BLM office. On tribal reservation lands, WS wolf 

25 damage management would only be conducted at the request of the tribe and under individual 

26 agreements with each sovereign tribal government.

27

28 Like Alternative 1, the Current Program, a strong information and education program, which 

29 focuses on nonlethal management, would be managed by WDFW with assistance from WS. 

30 This aspect would help ensure anyone with an interest in wolves is able to learn more about the 

31 species and stay informed about wildlife management activities. The WCMPW includes 

32 examples of education on wolf damage management issues such as public outreach, public 

33 meetings, information on the WDFW website, training, and discussions with individuals.

34

35 Several research projects are identified as necessary for future success of long-term wolf 

36 conservation and management. Monitoring and radio-collaring wolves would be included in this 

37 alternative for conservation and communication with the public. WS may assist in capturing 

38 wolves for radio-collaring.

39

40 Adaptive management would be used by WDFW to revise protocol according to changes in the 

41 phase of wolf recovery in Washington. Over time, wolves are expected to increase in number 

42 and expand their range within Washington, and therefore management approaches will be 

43 slightly modified as numbers increase (Wiles et al. 2011).

44

45 Finally, the WCMPW requires annual reporting to the WDFW on program implementation, thus 

46 WS would provide all information on its involvement with wolf captures including capture 

47 locations, methods used, and disposition to WDFW. 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 27
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 Formulating a strategy for wolf removal

2

3 Upon receiving a request to assist WDFW, USFWS, or tribes with capturing individuals from 

4 packs with confirmed repeated depredating wolves, WS would use its Decision Model (Figure3) 

5 (Slate et al. 1992) to determine the appropriate method of removal based on allowable methods 

6 (foot-hold traps, foot snares, neck snares, shooting, or aerial shooting) under the WCMPW, or 

7 similar guidance, and consultation with WDFW, USFWS, or tribes.

8

9 Figure 3. APHIS-WS Decision Model (Slate et al. 1992)

10 In selecting appropriate management techniques, consideration is given to: whether or not a 

11 collared or breeding wolf could be affected, location and land jurisdiction; land uses (such as 

12 proximity to urban or recreation areas); possible presence of humans, pets and non-target 

13 wildlife; feasibility of implementation of the various techniques; wolf movement patterns and 

14 life cycle; local environmental conditions such as terrain, vegetation, and weather; potential legal 

15 restrictions such as availability of tools or management methods; humaneness of the available 

16 options; and costs of control options (the cost of control in this proposal may be a secondary 

17 concern because of overriding environmental, management, and legal considerations).

18

19 When responding to requests from WDFW or tribes, lethal removal of wolves from packs 

20 causing repeated livestock depredation would only be done after unsuccessful attempts to use 

21 non-lethal methods had been documented. While the WCMPW dictates this for WDFW, WS 

22 would only agree to lethal removal on tribal lands under similar guidance.

23

24 Description of Lethal Methods Available to WS

25

26 This alternative includes all non-lethal methods described in Alternative 1, the Current Program, 

27 and adds the following lethal methods. These methods are specifically designed to lethally 

28 remove problem wolves in certain situations to stabilize, reduce, or eliminate damage. The 

29 amount of removal necessary to achieve a reduction in wolf damage varies according to the 

30 effectiveness of other damage management strategies, the damage situation, the level and 

31 likelihood of continued depredations, and WDFW or tribal final decision. The lethal wolf 

32 damage management techniques available to WS would include the use of foothold traps and 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 28
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 snares, followed by euthanasia, as recommended by the American Veterinary Medical 

2 Association (AVMA 2013, Julien et al. 2010). Additional lethal methods used under Alternative 

3 3 would include shooting from the ground as well as from fixed-wing aircraft or helicopters.

4

5 Shooting highly selective for the target species, and may be employed in conjunction with the 

6 use of auditory attractants (e.g., sounds of prey animals in distress or imitations of wolf 

7 vocalizations). Removal of one or two specific animals by shooting in the problem area can 

8 sometimes provide immediate relief from a predation problem. Shooting is often tried as one of 

9 the first lethal management options because it offers the potential of solving a problem more 

10 quickly and selectively than some other techniques, but it requires visually sighting the wolf 

11 within effective shooting distance. Shooting may sometimes be one of the only management 

12 options available if other factors preclude the setting of traps or snares.

13

14 Aerial Shooting typically involves visually locating suspected depredating individuals or packs 

15 from either a small single-engine fixed-wing aircraft or a helicopter, and shooting them from the 

16 aircraft. Depredation problems can often be resolved quickly and effectively through aerial 

17 shooting (e.g., by starting the aerial operation in the vicinity of a recent wolf kill, and catching 

18 the wolf or wolves when they return to feed on the livestock carcass). Cain et al. (1972) rated 

19 aerial shooting as “very good” in effectiveness for problem solving, safety, and lack of adverse 

20 environmental impacts. Smith et al. (1986) cited cost-effectiveness and efficacy as benefits of 

21 aerial shooting.

22 Good visibility is required for effective and safe aerial shooting operations, and relatively clear 

23 and stable weather conditions are necessary. Summer conditions limit the effectiveness of aerial 

24 shooting because the increased vegetative cover makes finding the animals more difficult, and 

25 the higher ambient air temperatures reduce air density, which affects low-level flight safety.

26 Aerial shooting is one of the most effective wolf damage management tools available.

27

28 Neck Snares can be used to kill, or to live-capture animals with a cable loop around the neck 

29 and the use of a “stop” to prevent full closure of the loop. Improved methods for use are being 

30 developed for live-trapping wolves and other carnivores (Olson and Tischaefer 2004). Snares 

31 are ordinarily not as affected by rain, snow, and freezing weather as foot-hold traps are. These 

32 devices offer a degree of selectivity based on the size of the cable loop and the height of the loop 

33 above ground level. They also offer a viable capture alternative to foot-hold traps during the 

34 winter months, when freezing temperatures combined with restricted blood circulation could 

35 result in damage to the wolf’s foot.

36

37 Sodium Pentobarbital (Beuthanasia®-D) is registered for euthanasia of dogs, and may legally 

38 be used for other animals if the animal is not intended for human consumption. Barbiturates 

39 depress the central nervous system in descending order, beginning with the cerebral cortex, with 

40 unconsciousness progressing to death. The primary advantage of barbiturates is the speed of 

41 action on the animal. Barbiturates induce euthanasia smoothly, with minimal discomfort to the 

42 animal (AVMA 2013). This method of euthanasia would likely only be used in the rare 

43 circumstance where an already sedated wolf was determined to have health or injury issues such 

44 that it would be most appropriate to euthanize the animal.

45

46

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 29
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 Measures used by WS to Minimize Environmental Risk

2

3 WS uses many standard operating procedures built into its programs which serve to minimize the 

4 potential for negative effects on the environment, including potential harm to humans and non5 target wildlife. While the WCMPW may be updated and permit conditions can change, 

6 currently, WS standard operating procedures, the WCMPW and/or WDFW permit conditions 

7 and conservation measures include, but are not limited to the following measures:

8

9 • Conspicuous, bilingual warning signs alerting people to the presence of traps and snares are 

10 placed at major access points when they are set.

11

12 • WS personnel are trained in identification of wolves and wolf sign.

13

14 • WS will maintain regular contact with appropriate state and federal agencies, reporting any 

15 sightings of wolves, wolf sign, or wolf depredations.

16

17 • WS will monitor traps every 24 hours while using foothold traps or snares.

18

19 • WS will incorporate pan-tension devices in foot/leg snares and foot-hold traps to reduce 

20 exposure of capture to smaller non-target animals. 

21

22 • WS will maintain regular contact with WDFW, USFWS, and/or tribes to keep apprised of 

23 locations and information on the presence of any T&E animals.

24

25 • Most wolf trapping will occur at or near depredation sites or along wolf trails to and from 

26 depredation sites. 

27

28 • Non-target animals captured are released at the site of capture unless the WS personnel

29 determine that they will not survive.

30

31 • AVMA (2013) recommended euthanasia procedures are followed, if feasible, to minimize 

32 pain and suffering. 

33

34 • Research continues to improve the selectivity and humaneness of management devices.

35

36 • WS work on Native American Indian tribal lands would conform to tribal government 

37 plans for wolf damage management. WS work on tribal lands would also closely mirror 

38 protocol outlined in WCMPW in regards to lethal and non-lethal management of wolf 

39 depredation.

40

41 • WS records and monitors all WS wolf removal through its Management Information 

42 System (MIS). Close coordination with and reporting to WDFW, USWFS, and/or tribes would 

43 occur for each wolf to be removed. More detail is provided under Monitoring in this section.

44

45 • Motorized vehicle access on public lands will be limited to permitted roads and areas. 

46

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 30
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 • Wolf damage management activities would be conducted only at the request of, and in 

2 coordination with the landowner or land management agency, and in the case of lethal control, 

3 per WDFW, USFWS, or tribal government decisions. Coordination provides for the 

4 communication necessary to avoid conflicts with land uses such as sensitive areas or public 

5 safety zones.

6

7 • The WS program is conducted under Cooperative Agreements and MOUs with federal and 

8 state agencies. National MOU’s with the BLM (1995) and USFS (2010) delineate expectations 

9 for wildlife damage management on public lands administered by these agencies.

10

11 General Measures to Protect Federally Threatened or Endangered Species

12 • In accordance with WS policy, foot-hold traps and foot snares would be placed 

13 farther than 30 feet from exposed carcasses to avoid inadvertent capture of 

14 eagles.

15 • WS WA would prioritize control methods to be used and would include 

16 consideration of non-target species in making these decisions. Where non17 target species of concern may be vulnerable, selective measures are generally 

18 preferred (such as shooting or darting). For large animals, culvert or cage traps 

19 may be preferred over other trapping methods. Foot-hold traps and foot snares 

20 are generally preferable to neck snares except under certain environmental 

21 conditions. WS WA will fully consider risk to non-target species in making 

22 these decisions.

23 • When conducting trapping, WS WA staff will consider target species, non24 target species, site-specific conditions, as well as all policy and regulatory 

25 requirements in determining types of traps, sets, lures or scents, and supporting 

26 hardware. The decision on whether to use a drag or stake will follow the 

27 considerations discussed earlier in the project description. 

28 • WS WA staff that are trapping large predators (e.g., wolves, cougars, and black 

29 bears), in areas where and when grizzly bear are reasonably likely to be present, 

30 will be trained in the identification of large predators (particularly in 

31 distinguishing between black bears and grizzly bears) and their sign. Training 

32 conducted by WS WA may be done in collaboration with the local USFWS or 

33 WDFW offices, or in conjunction with WS in other states. 

34 • Mapped landscape areas (designated for pygmy rabbit, lynx, grizzly bear, or 

35 federally listed wolves) will be reviewed on an annual basis with USFWS, 

36 WDFW, and other appropriate species experts to determine if an increase, 

37 decrease, or other modification is necessary. Applicable section 10(a)(1)(A) 

38 permits will be reviewed at that time to ensure continued applicability and 

39 listing of appropriate staff.

40 • Prior to trapping within mapped landscape areas (designated for lynx, grizzly 

41 bear, or federally listed wolves), WS WA will contact USFWS and/or WDFW 

42 for the most-recent information regarding the distribution of these species. WS 

43 WA will conduct pre-trapping reconnaissance in a manner that is directed 

44 toward finding sign of these species and will report any positive findings to 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 31
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 WDFW and USFWS. Personnel conducting such pre-trapping reconnaissance 

2 will be adequately trained in the identification of sign left by these species.

3 • Where pre-trapping reconnaissance discovers recent signs of certain species, or 

4 pre-trapping coordination reveals recent reliable observations of those species 

5 (i.e., grizzlies or lynx), alternative methods that are more selective will be used 

6 in lieu of trapping unless otherwise approved on a case-by-case basis by the 

7 USFWS after considering public safety and animal welfare.

8 • When trapping in grizzly bear, lynx, or federally listed wolf mapped landscape 

9 areas, or trapping for federally listed wolves, traps or snares should be checked 

10 by mid-morning, or as soon thereafter as possible in case of extenuating 

11 circumstances.

12

13 Measures Specific to Federally Listed Gray Wolves

14 • When doing pre-trap or operational reconnaissance for federally listed wolves 

15 and sign in areas that may contain wolves, howling will be conducted to 

16 facilitate detection if it is appropriate for the surroundings.

17 • While targeting coyotes and other predators, and where pre-trapping 

18 reconnaissance discovers recent sign or pre-trapping coordination reveals recent 

19 reliable observations of federally listed wolves, WS WA may resort to non20 trapping alternatives to achieve their objectives if capture of a wolf in that area 

21 is not deemed to be desirable. When capture of a wolf is deemed desirable by 

22 WS WA and wildlife agencies, WS WA will follow appropriate protocols 

23 provided by the wildlife agencies and all conservation measures that apply in 

24 case they inadvertently capture a wolf.

25

26 When operating within a mapped landscape area for federally listed wolves, WS 

27 will implement the following:

28

29 • Initial mapped landscape areas for federally listed wolves shall be the pack 

30 polygons maintained by WDFW and depicted on the WDFW website 

31 (http://wdfw.wa.gov/conservation/gray_wolf/packs/). These may change on 

32 a frequent basis as wolf distribution changes. Whether this system is 

33 working adequately will be assessed on an annual basis.

34

35 • Prior to controlling coyotes and other predators, WS WA would coordinate 

36 closely with USFWS and/or WDFW to ensure that field personnel have the 

37 most recent and most-reliable information on wolf activity in the action 

38 area. WS WA would conduct pre-trapping reconnaissance in a manner to 

39 detect any potential wolf sign prior to setting traps; this may include 

40 howling when appropriate. 

41 • When controlling predators smaller than wolves, traps and equipment must 

42 be of sufficient strength to adequately restrain any wolf without equipment 

43 failure, or allow the wolf to pull free from the trap. Stakes will be preferable 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 32
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 in these situations as staking may allow a captured wolf to pull-out of the 

2 trap more easily.

3 • When conducting predator control, no traps or snares shall be used within 

4 0.5 mile of occupied federally listed wolf den sites, known active 

5 rendezvous sites, or areas of recently documented pup activity from May 1 

6 to July 15, and within 1 mile of these areas from July 15 to October 1, 

7 unless approved on a case-by-case basis by the USFWS. 

8 • When conducting predator control, neck snares will not be used in mapped 

9 landscape areas without prior approval by USFWS.

10

11 When trapping federally listed wolves, WS will implement the following: 

12 • No traps or snares shall be used within 0.5 mile of occupied federally listed 

13 wolf den sites, known active rendezvous sites, or areas of recently 

14 documented pup activity from May 1 to July 15, and within 1 mile of these 

15 areas from July 15 to October 1, unless approved on a case-by-case basis by 

16 the USFWS. 

17 • Neck snares will not be used to capture federally listed wolves unless such 

18 use is approved by USFWS.

19 • Foot-hold traps will not be used to capture federally listed wolves in 

20 nighttime temperatures below 25°F unless otherwise approved by USFWS.

21 • When live capturing federally listed wolves, WS WA will use Livestock 

Protection Company #7 offset jaws or EZ-grip® 22 traps or equivalent, unless 

23 otherwise approved by the USFWS. At least 2 swivels will be used (one at 

24 trap and one at drag or stake).

25 • WS WA will ensure, in advance, that a means of safe transport for federally 

26 listed wolves (e.g., a large kennel) is readily available if medical treatment 

27 should be necessary. 

28 • WS WA staff that capture federally listed wolves will be trained in chemical 

29 immobilization and handling of wolves, or will be accompanied by WS WA 

30 staff that have been so trained.

31 • This consultation will not supplant or replace any other reporting 

32 requirements or informational commitments. WS will adhere to any 

33 guidelines and protocols cooperatively developed among WS WA, WDFW, 

34 and USFWS regarding responding to sightings, captures, mortalities, 

35 information about illegal activities, or other reports of gray wolves in 

36 Washington State. 

37

38 • When WS WA purposefully or incidentally captures federally listed wolves, 

39 in addition to adhering to the Response Guidelines, such capture will be 

40 managed in the following manner: 

41 o If the wolf is dead, WS will transport the carcass from the field and 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 33
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 report the death to the USFWS Washington Fish and Wildlife Office 

2 within 24 hours for data collection and disposal. The carcass will be 

3 kept as cold as feasible to preserve its integrity.

4 o If the wolf will not be able to survive in the wild and should be 

5 euthanized on site, the most-expedient means of euthanasia shall be 

6 employed consistent with the surroundings and situation. Following 

7 euthanasia, WS will transport the carcass from the field and report to 

8 the USFWS Washington Fish and Wildlife Office so that they can 

9 cooperatively collect data and dispose of carcass. The carcass will 

10 be kept as cold as feasible to preserve it integrity.

11 o If the wolf requires veterinary medical attention and transport is 

12 necessary and feasible, WS will pursue veterinary medical care and 

13 notify the USFWS Washington Fish and Wildlife Office for 

14 instructions regarding the best course of action following such care. 

15 If the wolf is a candidate for release, the details of such release shall 

16 be determined cooperatively with the WDFW and the USFWS.

17 o If the wolf is essentially uninjured and is a good candidate for further 

18 research, WS will follow protocols provided by the USFWS and 

19 WDFW for collecting samples, data, and any fitting with 

20 instrumentation. Chemical immobilization shall only be done by 

21 personnel experienced with handling wolves and certified to 

22 administer chemical immobilization drugs, unless otherwise 

23 approved by USFWS. 

24 o If the wolf is uninjured and no research is needed, WS will release 

25 the wolf as expeditiously as possible in a manner that protects the 

26 wolf and maximizes its chances for successful release and survival. 

27 Steps outlined in applicable protocols shall be followed. In some 

28 cases, this may require restraint and or chemical immobilization. 

29 Chemical immobilization shall only be done by personnel 

30 experienced with handling wolves and certified to administer 

31 chemical immobilization drugs, unless otherwise approved by 

32 USFWS.

33

34 Measures Specific to Grizzly Bear

35 • When conducting predator control and where pre-trapping reconnaissance or 

36 pre-trapping coordination with USFWS or WDFW reveals sign of grizzly bear 

37 or recent reliable observations, WS WA would resort to non-trapping 

38 alternatives to achieve their objectives unless otherwise approved on a case-by39 case basis by the USFWS after considering public safety and animal welfare.

40

41 • WS WA staff conducting trapping for large predators (wolves, cougars, or black 

42 bears) in areas where and when grizzly bear are expected to be present will 

43 carry a copy of a grizzly bear protocol including contact numbers and will 

44 follow its instructions in the event a grizzly bear is captured. In the event that 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 34
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 WS WA captures a grizzly bear, WS WA shall contact USFWS [Grizzly Bear 

2 Coordinator at (406) 240-6506] and an appropriate representative from WDFW. 

3 Arrangements would then be made to provide personnel from USFWS and/or 

4 WDFW to assist with handling the bear and determining the fate of the animal 

5 following the interagency guidelines already in place for recovery areas.

6

7 When operating within the grizzly bear mapped landscape areas during times 

8 that grizzly bears are expected to be out of the den (1 April to 30 November), 

9 WS WA will implement the following:

10

11 • Initial mapped landscape areas for grizzly bear will be the Federal lands 

12 within the North Cascades Recovery Zone; all lands within WDFW Game 

13 Management Units 108, 111, and 113; and all lands within the “Wedge” 

14 (named after the wedge-shaped part of northwestern Stevens County on the 

15 Canadian border between the Kettle and Columbia Rivers)(Game 

16 Management Unit 105). The mapped landscape areas and measures 

17 followed within those areas may increase, decrease, or change on an annual 

18 basis following review with the wildlife agencies and others. 

19

20 • WS WA would contact WDFW and USFWS to obtain most-recent grizzly 

21 distribution information. 

22

23 • WS WA would conduct pre-trapping reconnaissance in a manner sufficient 

24 to detect any potential grizzly sign prior to setting traps. Where pre-trapping 

25 reconnaissance discovers recent signs of grizzly bear or pre-trapping 

26 coordination reveals recent reliable observations, WS WA would resort to 

27 non-trapping alternatives to achieve their objectives unless otherwise 

28 approved on a case-by-case basis by the USFWS after considering public 

29 safety and animal welfare.

30

31 • WS WA staff participating in trapping of large predators (wolves, cougars, 

32 or black bear) will be trained in the identification of grizzly bears 

33 (particularly in distinguishing between black bears and grizzly bears) and 

34 grizzly bear sign. 

35 • Staff participating in trapping of large predators (wolves, cougars, or black 

36 bear) will be trained in implementation of techniques to avoid accidentally 

37 trapping grizzly bears.

38 • WS WA staff conducting capture of large predators (wolves, cougars, or 

39 black bear) will have been trained in chemical immobilization and in 

40 handling of large predators, or will be accompanied by WS WA staff that 

41 have been so trained.

42

43 • Use of foot snares and foot-hold traps for wolves, cougars, or black bears

44 will be limited. 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 35
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 o WS WA would prioritize the methods to be used with more-selective 

2 methods (e.g., shooting or aerial darting) being preferable. 

3 Generally, more-selective measures are attempted first in an overall 

4 step-wise progression of control. 

5 o If no recent sign or knowledge of recent observations exists, WS 

6 WA may use foot snares and/or foot-hold traps within the mapped 

7 landscape area. WS WA would provide written notification to 

8 USFWS (electronic mail is acceptable) in advance (or within 72 

9 hours if advance notice is not possible) that would include 

10 demonstration of why such use is necessary in that particular 

11 situation as well as any prior methods that were attempted during the 

12 current control effort. 

13 o WS WA will report, annually, the extent and results of such 

14 trapping, the rationale for the use of foot-hold traps or foot snares, 

15 any prior methods that were attempted, and the timing and extent of 

16 coordination with USFWS. 

17 o Such notifications will not be necessary when trapping wolves 

18 within the range of the federally listed wolf because coordination 

19 and notification will occur concurrently with the USFWS request to 

20 do such work.

21 • Neck snares will not be used for any species without prior approval on a 

22 case by case basis by USFWS, except for trapping coyotes within the 

23 following developed areas such as airports, urban/suburban developments, 

24 and animal-husbandry operations. For purposes of this measure, animal25 husbandry operations include, for example, barnyards, corrals, poultry 

26 operations, animal enclosures, and similar operations near houses. When 

27 used in these situations, neck snares will be placed judiciously to avoid areas 

28 a grizzly bear or cub could reach or access. Appropriate neck snare 

29 locations may include coyote crawl-ways under fences or buildings.

30 • When using formulated or commercial scents at trap sites, WS WA would 

31 utilize scents that are less attractive to grizzly bears (e.g., wolf urine vs. 

32 scents resembling natural bear foods).

33 • Where possible and practical, wolf traps would be anchored to a solid 

34 anchor such as a tree or, if such anchorage is not possible, to drags of at 

least 500 pounds dead weight or Livestock Protection Company® 35 heavy36 duty drag. 

37 • If foot snares are used for the capture of black bears, wolves, or cougars, all 

38 snares used will be grizzly sized snares with 1⁄4-inch steel cables anchored to 

39 fixed positions, and equipped with appropriate swivels. This is to ensure 

40 that if a grizzly bear is unintentionally captured the snare will hold the 

41 animal (rather than breaking away from the anchor and the grizzly bear 

42 escaping with the snare remaining on the leg) until it can be safely 

43 immobilized and released. 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 36
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 Monitoring

2

3 Wildlife Services role in monitoring would be to provide data to WDFW, USFWS, or tribes from 

4 its wolf damage management actions in Washington. Additionally, WS would provide 

5 information on wolf sightings, identification of wolf activity (tracks or scat), depredation 

6 investigations, telemetry searches, or any other monitoring activities. Wildlife Services monitors 

7 its program activities by using MIS, which compiles data on take locations, damages, methods 

8 used, and other information. Information from MIS can then be provided to cooperating 

9 agencies, used in wildlife management decisions and environmental analyses, and is available to 

10 the public.

11 2.4 Summary of Actions allowed by Alternative 

12

Table 1. Summary of WS activities that would be applied under each alternative (Adapted 

from WCMPW (Wiles et al. 2011, Table 9).

Activities

Alt. 1,

No 

Action

Alt. 2, 

Eliminate the 

Program

Alt. 3, 

Proposed 

Action

Investigate Wolf Depredation for WDFW, 

USFWS, and tribes. Yes No Yes

Non-lethal Technical Assistance (advice and 

information). Yes No Yes

Non-lethal Direct Assistance (non-injurious 

harassment). Yes No Yes

Non-lethal Direct Assistance (injurious

harassment). No No Yes

Lethal removal of non-federally listed wolves 

involved in repeated livestock depredation, as 

directed by WDFW or tribal authority.

No No Yes

Lethal removal of wolves that threaten human 

safety (per WDFW, USFWS, tribal, and/or ESA 

guidance).

No No Yes

Non-lethal capture for relocation, collaring, 

research, and/or monitoring. No No Yes

Assist WDFW, USFWS, and tribes with Wolf 

Monitoring. Yes No Yes

13

14 Table 1 identifies and compares the major components allowed under each of the alternatives. 

15 Specific criteria or conditions for actions, as required by the WCMPW, are summarized under 

16 the detailed descriptions of each alternative.

17

18

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 37
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 2.5 Alternatives Considered but Rejected from Detailed Analysis, with Rationale 

2

3 Integrated Wolf Damage Management without a Threshold of Loss Requirement

4

5 This alternative would differ from the proposed action in that it would have removed the 

6 threshold of livestock loss imposed by the WCMPW for agency removals of confirmed repeated 

7 depredating wolves. Under this alternative, WS would be able to remove wolves that simply 

8 threatened livestock or had killed fewer than the allowed threshold of loss. This alternative is 

9 not a viable alternative and cannot be selected based on the direction outlined in the WCMPW. 

10 Wolves are not yet sufficiently abundant in Washington to allow for more liberal removal actions 

11 and all actions must conform to the strategies allowed by the State. There is some flexibility in 

12 the WCMPW that would allow producers to take wolves under permit which enhances agency 

13 actions. This alternative may interfere with WDFW’s ability to achieve wolf conservation and 

14 management goals.

15

16 Use of Birth Control Strategies to Reduce Wolf Depredation on Livestock

17

18 Under this alternative, wolves would be sterilized or other contraceptive methods would be 

19 administered to limit the ability of wolves to produce offspring under the assumption that 

20 inability to reproduce would reduce wolf depredation on livestock. This strategy may interfere 

21 with WDFW and USFWS goals for conservation and delisting of gray wolves. In USDA 

22 (2011a), WS considered wolf contraception strategies that involve removal of all wolves in a 

23 pack that had caused repeated livestock depredation with the exception of the breeding pair, 

24 which would be live-captured, surgically sterilized, radio-collared, and released under the 

25 assumption that the pair would maintain and defend its territory against other wolves. WDFW

26 has not considered or included any wolf contraception strategies in the WCMPW, nor does WS 

27 have the authority to implement or require WDFW or the USFWS to test or implement such 

28 strategies.

29

30 Eradication

31

32 This alternative would direct all WS program efforts toward planned, total elimination of wolves. 

33 This alternative was not considered in detail because eradication of established wolf populations 

34 is contrary to state and federal efforts to protect and conserve wildlife and contrary to federal and 

35 state ESA requirements, WS objective is to reduce damage, not to engage in large-scale 

36 eradication or suppression, and eradication of wolves is not acceptable to most members of the 

37 public.

38

39 Agencies Exhaust All Non-lethal Methods Before Attempting Lethal Methods

40

41 Under this alternative, all non-lethal methods would have to be attempted and proven ineffective 

42 prior to using lethal wolf damage management methods even though, in the professional 

43 judgment of WS, WDFW, or USFWS personnel, some methods that would have to be attempted 

44 would be impractical (e.g., would incur costs in excess of value of resources protected), 

45 inappropriate (e.g., use of a light siren device in areas near human residences), or likely to be 

46 ineffective for the particular situation (e.g., situations where the predator appears to have 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 38
CHAPTER 2. DESCRIPTION OF ALTERNATIVES 

1 habituated). This alternative will not be addressed in detail for a number of reasons including: 1) 

2 time and resources of agencies and individuals experiencing damage may be unnecessarily 

3 expended when non-lethal methods are unlikely to be effective, based on circumstances, 

4 experience and professional judgment; 2) the potential that additional losses could be incurred 

5 while experimenting with non-lethal methods; and 3) experimenting with non-lethal approaches 

6 may not be appropriate in the rare instance of a wolf-related threat to human safety.

7

8 Lethal Only Program

9

10 Under this Alternative WS would only provide technical and operational assistance with lethal 

11 damage management techniques. In certain situations, non-lethal methods may provide short12 term or long-term solution to wolf damage problems. Prohibiting WS from using or providing 

13 technical assistance on effective and practical non-lethal wolf damage management methods is 

14 not in the best interest of the continued recovery of the species and is contrary to agency policy 

15 and directives (WS Directive 2.101). 

16

17 Sport Hunting and Trapping to Resolve Damages

18

19 WS has no authority to authorize or deny hunting or trapping season for wolves, nor is this 

20 allowable under federal ESA regulations. This issue is outside the scope of any decision that WS 

21 would make as a result of this EA.

22

23 Live Capture and Relocation of Depredating Wolves.

24

25 When individual wolves or wolf packs are already established as repeated depredators of 

26 livestock, moving them to another location may pose a high risk that the wolves would simply 

27 cause livestock predation losses in their new area. Wolves can and often do move long distances 

28 in relatively short periods of time and cannot be expected to stay in areas to which they are 

29 relocated. Thus, even if wolves could be relocated to remote wilderness or sparsely inhabited 

30 areas away from livestock, they cannot be relied upon to stay in such areas and avoid further 

31 livestock depredation problems. WS has no authority to authorize or require WDFW, USFWS, 

32 or tribes to choose this alternative, and this issue is outside the scope of any decision that WS 

33 would make as a result of this EA.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 39
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

1 CHAPTER 3 - ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

2

3 3.1 Issues Driving the Analysis 

4

5 The following environmental issues or resources have been evaluated in this EA to help 

6 determine the impacts of the proposed action on the environment and to compare the alternatives

7 in Chapter 4.

8

9 • Impacts on wolf populations - What might be the impact of the proposed action be on the 

10 growing Washington wolf population, in eastern Washington and statewide? What would be 

11 the cumulative effects of the proposal?

12

13 • Impacts on non-target animals and human safety - Would there be impacts on other 

14 species besides wolves? Could the program affect pets? Might the program have adverse or 

15 beneficial effects on federally protected species? Are there risks to human safety?

16

17 • Social and Aesthetic Perspectives – How acceptable are the alternatives to stakeholders? 

18 How is humaneness perceived? What are the implications for the aesthetic value of wolves?

19

20 • Effectiveness – A discussion on the effectiveness of the alternatives will reveal how well the 

21 alternative meets the purpose and need for action. This issue is not an environmental issue, 

22 but it is an important management consideration that will be weighed with the environmental 

23 findings to make an informed decision.

24

25 3.2 Issues Not Analyzed in Detail, with Rationale 

26

27 Appropriateness of preparing an EA (rather than an EIS) for a state program rather than 

28 preparing multiple EAs for smaller, more site-specific areas

29

30 Federal agencies have the discretion to determine the geographic scope of their NEPA analyses 

31 [Kleppe v. Sierra Club, 427 U.S. 390, 414 (1976)] and WS has determined that preparation of 

32 this EA to address wolf damage management in Washington is appropriate and consistent with 

33 state (Wiles et al. 2011) and federal wolf management objectives and plans. If a determination is 

34 made through this EA, that the proposed action would have a significant impact on the quality of 

35 the human environment, then an EIS may be prepared in compliance with NEPA.

36

37 Effects of wolf removal on a pack structure

38

39 Pack resilience to mortality is inherent in wolf behavioral adaptation and reproductive 

40 capabilities (Brainerd et al. 2008). Wolf populations have sustained human-caused mortality 

41 rates of 30 to 50% without experiencing declines in abundance (Keith 1983, Fuller et al. 2003). 

42 In addition, Brainerd et al. (2008) found that 62% of packs in recovering populations retained 

43 territories despite breeder loss, and of those that lost territories, one-half became re-established. 

44 Pup survival is primarily dependent on size of pack and age of pup because multiple pack 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 40
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

1 members feed pups despite loss of a breeder. Pup survival in 84% of packs with breeder loss 

2 was similar or higher than packs without breeder loss (Mech and Boitani 2003).

3

4 WDFW, USFWS, or tribes are responsible for determining when a wolf shall be removed from a 

5 pack. This will occur whether WS assists with removal or not.

6

7 Ecological effects of wolf removals

8

9 Wolf removal during damage management actions, combined with other forms of mortality,

10 would not result in a negative effect to wolves in WA, because if WS did not remove the wolf, 

11 WDFW would conduct the removal or contract with a private party to conduct the removal. 

12 Wolf removal as a mechanism of wolf damage management is expected to support wolf 

13 conservation and management as discussed in the WCMPW (Wiles et al. 2011). Based on a 

14 review of available literature in USDA (2011a), and Mech (2012), we find no reason to expect 

15 that wolf removals by WS would result in significant adverse effects on the quality of the human 

16 environment because of possible wolf-related changes in ecosystems.

17

18 WDFW, USFWS, or tribes are responsible for determining when a wolf shall be removed from a 

19 pack. This will occur whether WS assists with removal or not.

20

21 Producers should consider that wolf predation losses are a cost of doing business

22

23 Livestock producers recognize that some level of predation losses are likely to occur, in spite of 

24 their own and government (state or federal) efforts to reduce the amount of losses. The 

25 WCMPW is not setting expectations of preventing all losses, nor does it prescribe lethal wolf 

26 damage management as a solution to all depredation incidents. The WCMPW established an 

27 integrated approach to resolve wolf damage complaints. In some situations, the use of non-lethal

28 methods alone may be adequate for resolving wolf depredation complaints, but there will be 

29 situations which require lethal measures. Most instances of wolf predation on sheep, for 

30 example, occur in spite of sheep producers’ use of herders and livestock guarding dogs to help 

31 protect the sheep from predation. Livestock producers incur direct losses and indirect losses

32 from wolves without always resulting in wolf removal. These include harassment of livestock 

33 by wolves, fence repairs after wolves chase livestock through fences, costs to gather and regroup

34 livestock dispersed by wolves, and extra costs when producers have to pay for feed because 

35 livestock are removed from grazing pastures to minimize risks from wolves. These and other 

36 indirect effects that wolves have on livestock are discussed under Section 1.2.

37

38 Tribal Lands

39

40 Tribal wildlife managers with responsibilities to protect and manage treaty-reserved wildlife 

41 resources in Washington may meet wolf management needs in their areas of interest and 

42 influence. Tribal leaders may choose how to manage wolf issues within their lands and may or 

43 may not coordinate with the WCMPW.

44

45 WS contacted the 29 federally recognized tribes in Washington to solicit tribal concerns for this 

46 EA. No issues were provided from these tribes. Because extensive outreach occurred during the 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 41
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

1 preparation of the WCMPW, no new issues arose from the outreach and consultation associated 

2 with this EA.

3

4 As discussed under the proposed action, WS determined that WS work on tribal lands would 

5 conform to similar depredation management protocols as allowed under the WCMPW and 

6 USFWS regulations. Therefore, work on tribal lands in Washington would not add new issues or 

7 change the analysis of effects considered in detail.

8

9 Effects on Wilderness, Wilderness Study Areas, National Parks, State Parks, and National 

10 Monuments

11

12 Wolf removals would not occur in National Parks or National Monuments. Because individual 

13 wolves may be removed from surrounding areas, the potential for a slight temporary effect on 

14 users of National Parks and National Monuments may occur by reducing the opportunity to view 

15 or hear a wolf that may have otherwise traveled into the protected area, however the effect would 

16 be insignificant because wolf populations would be expected to continue to grow for the reasons 

17 discussed in the WCMPW and in Chapter 4.

18

19 Wolf removal may occur in federally designated wilderness areas or Wilderness Study Areas. 

20 The Wilderness Act (16 U.S.C. §§ 1131-1136) established a national preservation system to 

21 protect areas “where the earth and its community life are untrammeled by man” for the United 

22 States. Wilderness areas are devoted to the public for recreational, scenic, scientific, educational, 

23 conservation, and historical use. This includes the grazing of livestock where it was established 

24 prior to the enactment of the law (Sept. 3, 1964). The Wilderness Act did leave management 

25 authority for fish and wildlife with the States for those species under their jurisdiction. Some

26 portions of wilderness areas in Washington have historic grazing allotments and WS may 

27 conduct limited wolf removal for protecting livestock or human safety as directed by WDFW in 

28 accordance with the WCMPW and coordination with the Regional Forester. 

29

30 In accordance with Forest Service Manual 2323.33c, the Regional Forester may approve predator 

31 damage management on a case-by-case basis to protect livestock and human health and safety in 

32 designated wilderness. The Regional Forester will only approve the action when removing the 

33 offending animal would not diminish wilderness character. Any wolf control in Wilderness 

34 Areas would be coordinated with the Regional Forester under annual WDM work plans as 

35 defined in the MOU between the USFS and WS (Appendix B). Proposed WS work plans are 

36 reviewed by USFS during the work planning process to ensure that areas of conflict do not exist. 

37 Therefore, WS wolf damage management would have no negative effect on wilderness character 

38 or management objectives. It would not impair the wilderness designation by Congress.

39

40 WS conforms to Revisions and Clarifications to H-8550-1, Interim Management Policy for 

41 Lands Under Wilderness Review (March 19, 2004 memorandum (No. 2004-140) from BLM 

42 Director to all Washington and Field Office Officials). WS follows BLM's Interim Management 

43 Policy for Lands Under Wilderness Review, H-8550-1 (1995), and the MOU between BLM and 

44 WS.

45

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 42
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

1 WS proposed activities on lands under wilderness review (WSAs) do not conflict with BLM 

2 management objectives as set forth in the RMPs. In WSAs, WS work is limited to actions 

3 allowed in BLM’s Interim Management Policy for Lands Under Wilderness Review (H-8550-1, 

4 III. G. 5., July 5, 1995), as revised (BLM 2004). These documents provide, in part, that wildlife 

5 damage management may be permitted in certain circumstances in order to protect domestic 

6 livestock and reduce human health or safety risks. Coordination is required in order that wildlife 

7 damage management activities planned in WSAs meet the non-impairment criteria. Proposed 

8 WS AWPs are presented for review by BLM during the work planning process to ensure that 

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

10 agents could remove the wolf. Therefore, WS actions would have no effect on wilderness 

11 characteristics such as size, naturalness, solitude, aesthetics, primitive or unconfined type of 

12 recreation, supplemental values, and the possibility of returning the area to a natural condition as 

13 stated in BLM’s Wilderness Inventory Handbook from 1978 and the Interim Management Policy 

14 for Lands under Wilderness Review. (H-8550-1, July 5, 1995)

15

16 For the reasons discussed above, WS’ proposed wolf damage management activities would not 

17 negatively impact Wilderness or WSAs.

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

19

20 Issuance of permits to landowners to take wolves

21

22 Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 

23 federally listed are managed by the USFWS. WS’ has no authority to issue permits to 

24 landowners and livestock producers and this outside the scope of any decision that WS would 

25 make as a result of this EA. Actions by others to address wolf conflicts have been considered 

26 under the cumulative impacts discussions in Chapter 4.

27

28 Desire for or opposition to a hunting season for wolves

29

30 WS has no authority to authorize or deny hunting or trapping season for wolves, and this issue is 

31 outside the scope of any decision that WS would make as a result of this EA. 

32

33 Appropriateness of livestock grazing on public lands

34

35 Regulating or authorizing livestock grazing on public lands is the responsibility of the respective 

36 public land management agencies, not WS.

37

38 Appropriate population level for wolves in Washington

39

40 Wolves that are federally delisted are managed by the WDFW whereas wolves that remain 

41 federally listed are managed by the USFWS. Appropriate population levels are determined by 

42 each agency, not WS, and this is outside the scope of any decision that WS would make as a 

43 result of this EA. 

44

45

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 43
CHAPTER 3. ISSUES IMPORTANT TO THE ANALYSIS OF IMPACTS

1 Other resources

2

3 The actions discussed in this EA do not involve ground disturbance or construction or alteration 

4 of vegetation. Therefore, the following resource values are not expected to be significantly 

5 affected by the alternatives analyzed: soils, geology, minerals, water quality/quantity, flood 

6 plains, wetlands, visual resources, air quality, prime and unique farmlands, aquatic resources, 

7 vegetation, cultural resources or special management areas. There are no significant irreversible 

8 or irretrievable commitments of resources other than a minor use of fossil fuels to operate 

9 vehicles. These resources will not be analyzed further.

10

11 3.3 Evaluation Methodology 

12

13 Each issue will be evaluated under each alternative and the direct, indirect, and cumulative 

14 effects will be disclosed as applicable. NEPA describes the elements that determine whether or 

15 not an impact is “significant”. Significance is dependent upon the context and intensity of the 

16 impact. The following factors will be used to evaluate the significance of the impacts in this EA 

17 that relate to context and intensity (adapted from USDA (1997, revised) for this proposal):

18

19 Magnitude of the Impact (size, number, or relative amount of impact) (intensity) –

20 Quantitative analysis is used where possible as it is more rigorous and is based on all known 

21 sources of wolf mortality and actions provided for under the WCMPW. Magnitude may be 

22 determined quantitatively or qualitatively;

23

24 Duration and Frequency of the Impact –

25 Temporary, seasonal impact, year round or ongoing (intensity);

26

27 Likelihood of the Impact –

28 (intensity);

29

30 Geographic Extent –

31 Limited to the local unit area or to the management zone (context); and

32

33 Legal Status -

34 Of the species that may be affected; and conformance with regulations and policies that protect 

35 the resource in question (context).

36

37 The analyses in Chapter 4 use the WCMPW and USFWS guidance/regulations as the 

38 environmental baseline under which wolves are managed. The analyses do not attempt to 

39 identify wolf populations or trends or whether a wolf should or should not be taken, as that is the 

40 responsibility of WDFW, USFWS, or tribes as the appropriate resource managers. The analyses 

41 are limited to what effects WS may have if WS removes a wolf compared to that of WDFW, 

42 USFWS, tribes, or their agents taking a wolf at the decision and request of WDFW, USFWS, or 

43 tribes. The cumulative effect on the gray wolf population in Washington includes past, present,

44 and reasonably foreseeable future actions of WS and others.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 44
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

2

3 Chapter 4 provides information needed for making informed decisions on the wolf damage 

4 management objectives identified in Chapter 1. This chapter uses the four issues identified in 

5 Section 3.1 as the evaluation criteria. Each issue will be analyzed for its environmental 

6 consequences under each alternative. 

7

8 Direct, indirect, and cumulative impacts are discussed in relationship to how WS’ actions under 

9 that alternative may affect the wolf population, non-target impacts, perspectives of human social 

10 values and aesthetics, and effectiveness relative to if WS did not take any action. The 

11 effectiveness of the alternatives is also discussed as a measure for comparison in meeting the 

12 purpose and need for action.

13

14 4.1 Alternative 1 – No Action 

15

16 The “No Action” Alternative is for WS to continue the existing wolf damage management 

17 program as is. This is the environmental status quo, a required NEPA component, a viable 

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

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

20 investigations of livestock conflicts, providing the public with advice and recommendations on 

21 the appropriate use of non-lethal methods to protect livestock from wolf damage, and performing 

22 non-lethal control actions to reduce wolf damage.

23

24 WDFW would implement measures in the WCMPW and governing regulations and would 

25 remove target wolves themselves. Tribes with management authority of wolves could

26 implement measures according to their wildlife policies. Thus, the cumulative effects of such 

27 actions are the current environment under which wolves exist, and are discussed as the 

28 environmental baseline, or the environmental status quo.

29

30 4.1.1 Impact on wolf population 

31

32 Gray Wolf Population in Washington

33

34 As of March 2013, there were ten confirmed packs in Washington: seven packs in the Eastern 

35 Washington, three packs in the Northern Cascades management area, and none in the South 

36 Cascades & Northwest Coast management area (Figure 2). There are also indications of two 

37 additional packs in the Eastern Washington management area two bordering packs (one near 

38 Walla Walla and another in the north Cascade Mountains (Figure 2). A least a few solitary 

39 wolves likely occur in other scattered locations of Washington.

40

41 Continued wolf movement into Washington from adjacent states is likely given the population of 

42 wolves in the state of Idaho which identified 101 documented wolf packs and an estimated 

43 population of 746 wolves, with additional packs overlapping along bordering states (IDFG and 

44 Nez Perce Tribe 2012). The wolf population in Washington is expected to grow as Washington 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 45
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 wolves continue to reproduce and as wolves from other states and Canada enter Washington

2 through natural dispersal. The Idaho portion of the NRMDPS is expected to continue to supply 

3 new dispersing wolves to Washington, which will diversify the gene pool and fill in home ranges 

4 that become vacant due to lethal control, natural mortality, unintended mortalities, or westward 

5 dispersal. 

6

7 The rate of wolf dispersal into and throughout Washington cannot be predicted. The ability of 

8 wolves to reach areas of habitat outside northern and eastern Washington is assumed. There are

9 documented wolf packs as far west as the Cascade Mountains (Figure 2), but resident wolves or 

10 packs have not yet been confirmed west of the Cascade Mountains. 

11

12 As wolf activity is documented through discovery of individual wolves or wolf pack activity, 

13 WDFW or USFWS will continue to radio-collar and monitor individuals. By monitoring and 

14 observing wolves regularly, determinations regarding the habitats they select and occupy will be 

15 possible. Management decisions will be evaluated for reducing conflicts while promoting 

16 recovery.

17

18 Wolves can occupy a variety of habitats provided adequate prey is available and they are 

19 tolerated by humans (Wiles et al. 2011). The specific habitat chosen will be determined by prey 

20 availability and human tolerance and probably will include national forests, parks, and 

21 wilderness areas, designated roadless areas, and areas with low densities of open roads (Wiles et 

22 al. 2011). Areas in the Cascade Mountains, northeastern Washington, Olympic Peninsula, and 

23 Blue Mountains meet these criteria. 

24

25 Direct effect on the gray wolf population

26

27 WS would have no effect on individual wolves or wolf conservation and management in 

28 Washington under the No Action alternative, other than as a provider of technical assistance and 

29 select non-lethal control to WDFW and landowners. In this capacity, WS’s assistance would 

30 help ranchers minimize wolf damage, thereby reducing the need for some lethal removal. Lethal 

31 removal would still be required and conducted by WDFW and/or tribes.

32

33 Cumulative effects on the gray wolf population

34

35 WS’ actions would have no negative effects on wolf populations. The wolf population in 

36 Washington is expected to increase and expand throughout the state, and livestock damage is 

37 also expected to increase and expand (Wiles et al. 2011). WDFW wrote that if WS was not able 

38 to assist further, it WDFW would, by necessity, respond to wolf damage and would remove 

39 problem wolves as defined in the WCMPW (Appendix A). Further, WDFW indicated that it 

40 may remove more wolves that otherwise necessary (as compared to the Proposed Alternative) 

41 since it would need to refocus its efforts away from proactive nonlethal measures. Ultimately, 

42 this alternative could hamper WDFW wolf recovery and conservation efforts (Appendix A). 

43

44

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 46
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 4.1.2 Impacts on non-target animals and human safety 

2

3 Non-target animals

4

5 WS would have no effect on non-target animals or human safety under the No Action alternative. 

6

7 Wolf removal actions by WDFW are expected to continue. The potentially harmful non-lethal or 

8 lethal methods available to WS are also available to WDFW. 

9

10 WS’s use of traps and foot snares in Washington has not presented any safety risks to people

11 (MIS 2012). This conclusion was made on the national WS program by a formal risk assessment 

12 of WS methods (USDA 1997, Appendix P). It is unlikely that this risk would be higher if 

13 WDFW or its agents applied these methods. 

14

15 4.1.3 Social and Aesthetic Perspectives 

16

17 Wildlife generally is regarded as a source of economic, recreational, and aesthetic benefits 

18 (Decker and Goff 1987), and the mere knowledge that wildlife exists is a positive benefit to 

19 many people. Under this alternative, WS would not take action to remove wolves and would not 

20 directly affect those with strong opinions on this aspect of wolf damage management or on 

21 humaneness, nor would WS have any positive or negative effect on the ability of the public to 

22 potentially experience wolves in the wild. The No Action alternative would not preclude 

23 WDFW and others taking actions to resolve wolf depredation, using lethal means where 

24 authorized.

25

26 Humaneness

27

28 Under this alternative, wolves could be trapped or shot by experienced WDFW personnel as 

29 humanely as possible using the best methods available. All activities would be conducted in 

30 accordance with Washington Administrative Codes and WDFW guidelines to minimize the 

31 amount of time target and non-target animals remain in traps, and improve the likelihood that a 

32 non-target animal may be released unharmed. WS would not lethally remove or physically harm 

33 any wolves including during non-lethal harassment.

34

35 Wolves could be killed by livestock producers, where they are federally delisted, under WDFW

36 permit or when caught in the act of attacking or killing livestock (WAC 232-36-05100B). The 

37 humaneness of private individuals shooting wolves would depend on the skill of the individual 

38 and their ability to make a quick and efficient kill. 

39

40 Some individuals would consider this alternative inhumane because they oppose all lethal 

41 methods of damage management. Others will be opposed to this alternative because they object 

42 to specific lethal wolf damage management methods like traps and cable restraints and perceive 

43 these methods as being unjustifiably cruel and inhumane. Some individuals would prefer that 

44 cage traps be used to capture wolves and would perceive this method as being more humane than 

45 traps and cable restraints. Unfortunately, the use of cage traps to capture wolves is impractical 

46 and ineffective because it is extremely difficult to get a cage trap big enough for an adult wolf 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 47
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 into remote locations, and because it is rare to capture an adult wolf in a cage trap (USDA 2006). 

2 Individuals with animals that have been injured, threatened, or killed by wolves may see this 

3 alternative as being acceptable because it includes necessary lethal actions to help prevent further 

4 injuries to their livestock and pets.

5

6 Finally, livestock owners feel that they have a right to protect their property, and may consider it 

7 unacceptable that their domesticated animals be subjected to harm by wolves. 

8

9 Aesthetic Effects 

10

11 Aesthetics is the philosophy dealing with the nature of beauty, or the appreciation of beauty. 

12 Therefore, aesthetics is truly subjective, dependent on what an observer regards as beautiful. 

13 Direct benefits are derived from a user’s personal relationship or direct contact with wildlife and 

14 may include either consumptive (e.g., using or intending to use the animal such as in hunting or 

15 fishing) or non-consumptive use (e.g., observing or photographing animals) (Decker and Goff 

16 1987). Indirect benefits, or indirect exercised values, arise without a human being in direct 

17 contact with an animal and are derived from experiences such as looking at pictures or videos of 

18 wildlife, reading about wildlife, or benefiting from activities or contributions of animals such as 

19 their use in research (Decker and Goff 1987). Two forms of indirect benefits exist according to 

20 Decker and Goff (1987): bequest and pure existence. Bequest benefits arise from the belief that 

21 wildlife should exist for future generations to enjoy; pure existence benefits accrue from the 

22 knowledge that the animals exist in the human environment (Decker and Goff 1987) or that they 

23 contribute to the stability of natural ecosystems (Bishop 1987). 

24

25 Some people directly affected by problems caused by wolves insist on the lethal removal of the 

26 problem animal(s) from the area where the conflict occurs. Others have the view that all wildlife 

27 involved in conflicts should be captured and relocated to another area to alleviate the problem. 

28 Individuals not directly affected by a conflict may be supportive of affected humans, neutral, or 

29 totally opposed to any removal of wildlife from specific locations or sites. 

30

31 Those who oppose removal of wildlife may do so because of emotional or spiritual ties to the 

32 animals, which are similar to the bonds that may exist between a human and a pet. Some may 

33 totally oppose wolf damage management, especially if lethal methods are used, and want 

34 management agencies to teach tolerance of wolves causing conflicts. These individuals generally 

35 believe that individual animals have inherent value and should not be killed to meet the desires 

36 of man-kind. They may also feel that individual animals have rights similar to those of humans 

37 and that, if it is inappropriate to treat a human in a given manner, then it is also inappropriate to 

38 treat an animal in that manner. 

39

40 Under this alternative WS would not remove wolves. WDFW would still remove problem 

41 wolves (Appendix A), as could tribal authorities. The ability to view and aesthetically enjoy 

42 wolves at a particular site could be temporarily limited when the wolves are removed. New 

43 animals would most likely reoccupy the site in the future if suitable habitat exists, although the 

44 length of time until new wolves arrive is variable, depending on the habitat type, time of year, 

45 and population density of wolves in nearby areas. An objective of the WCMPW is to conserve 

46 wolves to the point of recovery, while managing conflicts. Given that wolves are expected to 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 48
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 continue to expand in number and range in Washington, the current program alternative and 

2 environmental status quo will not jeopardize the viability of the wolf population, thus 

3 opportunities to view, hear, and aesthetically enjoy wolves will likely be available to the public 

4 and grow over time as wolves reach recovery and management stages. 

5

6 4.1.4 Effectiveness 

7

8 The integrated and adaptive approach employed by WDFW, USFWS, or tribes under the 

9 WCMPW could incorporate the use of lethal and non-lethal measures to stop or reduce the 

10 likelihood of wolf damage. In assessing the effectiveness of various management approaches to 

11 dealing with wolf predation on livestock in the NRM area, Bangs et al. (2009) concluded that 

12 while non-lethal tools were temporarily helpful in some situations, they were generally 

13 ineffective, particularly in areas that simply would have too many livestock conflicts for wolf 

14 packs to persist. That is, scaring wolves away from one specific location in an area with large 

15 numbers of livestock everywhere else simply results in the wolf conflicts with livestock in 

16 adjacent areas where focused non-lethal efforts are not being employed or as ardently. Bangs et 

17 al. (2009) also concluded that lethal management of problem wolves was usually effective in 

18 reducing conflict because it: 1) enhanced effectiveness of non-lethal control measures, 2) 

19 interrupted use of livestock as food by surviving wolves, 3) removed offending individuals, 4) 

20 reduced wolf density in conflict areas, 5) eliminated packs where repeated livestock depredations 

21 had been occurring, 6) helped to keep wolf packs out of unsuitable habitat, 7) made surviving 

22 pack members temporarily avoid or be more wary of people and/or areas with livestock, 8) 

23 reduced the pack’s overall need for food, 9) made it more difficult for the fewer remaining pack 

24 members to kill larger prey like adult cattle or attack calves protected by cows, 10) increased the 

25 detection rate of subsequent depredations because livestock carcasses were consumed more 

26 slowly (so additional control could be applied more rapidly), 11) reduced compensation and 

27 control costs, and 12) moderated some of the public anger over wolf predation on livestock. 

28 Mech (1995) similarly concluded that in most circumstances, lethal removal of wolves was 

29 usually the only practical approach to resolving incidents of wolf predation on livestock. 

30

31 Karlsson and Johansson (2009) reviewed data on livestock predation by brown bears, wolves and 

32 lynx on farms in Sweden and concluded that the risk of predation greatly increased during the 

33 first several weeks after an initial predation incident. They suggested that control efforts, 

34 whether lethal or non-lethal, would be most effective if applied during this period of time 

35 following an initial depredation event. Bradley (2004) found that after partial or complete wolf 

36 pack removal, depredations usually ceased for the remainder of the given grazing season. 

37 However, the majority of packs that were partially removed (68%) depredated again within the 

38 year. Where entire packs were removed, the rate of re-colonization was high (70%) and most re39 colonization (86%) occurred within a year of removal of the previous pack; most packs (86%) 

40 that recolonized the same area were implicated in depredations. Packs in which breeders were 

41 removed were no less likely to cause depredations again within the year than packs with non42 breeders removed. 

43

44 Although non-lethal methods are often only temporarily effective, they may sometimes offer 

45 protection for a long enough period of time to protect a resource when it may be most vulnerable. 

46 An example is the use of the RAG box in small calving pastures. Breck et al. (2002) reported 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 49
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 that this frightening device, activated by the radio signal from an approaching radio-collared 

2 wolf, was effective in keeping a radio-collared wolf pack away from several small calving 

3 pastures in central Idaho for 60 days. However, this device is only useful in those cases where at 

4 least one and preferably multiple wolves in the pack are radio-collared, and it is only useful for 

5 protecting relatively small areas. Fladry has also been used to deter wolves for up to 60 days 

6 before the wolves habituated to it and began killing livestock again (Musiani et al. 2003). One 

7 consideration in the use of these temporarily effective non-lethal methods, is, that if wolves will 

8 eventually be lethally removed anyway (after habituating to the frightening stimulus), the 

9 investment of time and resources in the non-lethal efforts may not be practical. 

10

11 One of the most effective non-lethal deterrents to wolf predation may be the on-site presence of 

12 humans who remain near the livestock and are vigilant in trying to detect the presence of wolves 

13 so they can be consistently frightened away (Shivik 2004). These efforts can be more effective if 

14 there are radio-collared wolves in the area and the livestock guardian personnel make use of 

15 radio-telemetry receivers to detect the nearby presence of wolves. The costs to provide 24/7 

16 human presence around livestock would ordinarily be cost-prohibitive for livestock producers, 

17 but in some situations, outside parties with an interest in wolf conservation have provided such 

18 assistance at no cost to livestock producers, in order to promote greater tolerance for wolves. 

19 The Defenders of Wildlife have paid for such efforts in the Big Wood River drainage of central 

20 Idaho during several recent summer grazing seasons, and while these efforts have not been 100% 

21 effective in eliminating wolf problems, they appear to have been effective in reducing the 

22 number of wolf attacks on sheep and livestock guarding dogs in this area (USDA 2010). 

23

24 Bangs and Shivik (2001) reported that while some non-lethal methods may be temporarily 

25 effective, many are expensive to implement and none available at the time of their report were 

26 widely effective. Many non-lethal methods of preventing livestock losses to wolves have been 

27 tried and abandoned in the United States and Europe because of lack of effectiveness. Use of 

28 guard dogs alone has been tried against wolves in Minnesota with only limited success (Fritts et 

29 al. 1992). Coppinger and Coppinger (1996) showed the dominance of wolves over livestock 

30 guarding dogs in direct confrontations, and Coppinger and Coppinger (1996) and Bangs et al. 

31 (1998) reported that wolves have killed livestock guarding dogs. Wolves have also been 

32 translocated to other areas, but many either returned to where they were caught or became a 

33 problem elsewhere (Fritts et al. 1984, 1985). Mech et al. (1996) concluded that where wolf 

34 populations are large and secure, translocation has little value in wolf management. Aversive 

35 conditioning (Gustavson and Nicolaus 1987, Shivik and Martin 2001, Shivik et al. 2003) has not 

36 yet proven effective with wild wolves (Fritts et al. 1992). Electric fencing may hold some 

37 promise for protecting livestock from wolves, but fences tested for coyotes have been extremely 

38 expensive, high maintenance, and better suited for small areas (Dorrance and Bourne 1980, Nass 

39 and Theade 1988, Paul and Gipson 1994), rather than range operations. 

40

41 In looking at the possible role of livestock husbandry practices in reducing wolf predation, 

42 Bradley and Pletscher (2005) assessed multiple factors potentially related to wolf depredations 

43 on cattle in fenced pastures in Montana and Idaho. They concluded there was no relationship 

44 between depredations and carcass disposal methods, calving locations, calving times, breed of 

45 cattle, or the distance cattle were grazed from the forest edge. They did find that depredations 

46 were more prevalent in pastures where elk were more likely to occur, where the pastures were 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 50
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 larger in size, had more cattle, and where cattle were grazed farther from residences than 

2 pastures without depredations. Mech et al. (2000) likewise concluded there were essentially no 

3 differences in husbandry practices between farms in Minnesota that suffered repeated wolf 

4 depredations, as compared to similar operations which experienced no depredations, and that 

5 farms with cattle farther from human habitation suffered more losses. 

6

7 Haight et al. (2002) and Cochrane et al. (2003) reported on a model developed to assess three

8 different strategies for reducing wolf predation on livestock, including: 1) reactive management, 

9 where wolf removal occurred soon after depredations occurred, 2) delayed reactive management, 

10 where wolf removal occurred in the winter months prior to the grazing season in areas with a 

11 history of previous depredations, and 3) population-size management, where wolves were 

12 removed annually in the winter months from all areas near farms. The authors’ concluded that: 

13 1) each of these approaches reduced predation by about half compared with no action, 2) delayed 

14 reactive management and population-size management actually removed fewer wolves than 

15 reactive management because wolves were removed in winter before pups were born, and 3) 

16 population-size management was least expensive because repeated annual removal kept most 

17 territories near farms free of wolves. The WCMPW allows lethal methods to only be used as a 

18 reactive approach. 

19

20 In conclusion, non-lethal methods are used and recommended but not always successful in 

21 stopping or reducing damages, especially over time and must be supplemented with lethal 

22 methods. WDFW’s approach is to allow for limited lethal removal of wolves after they have 

23 been confirmed to have been involved in repeated livestock depredation. WDFW has indicated 

24 that it would target wolves for lethal control, similar to the proposed action, however without 

25 additional assistance from WS, service to landowners may be reduced or delayed and WDFW 

26 would have to redirect their personnel from conservation and recovery focus to lethal removal, 

27 thus wolf depredation on livestock may increase and overall conservation and recovery may be 

28 slowed. 

29

30 4.2 - Alternative 2 – Eliminate the Current Wolf Assistance Program

31

32 Under Alternative 2, the Eliminate the Current Wolf Assistance Program Alternative, WS would 

33 not provide any wolf assistance to WDFW, other public agencies, or private individuals within 

34 Washington. WS would not distribute available equipment or assist landowners with the 

35 implementation and use of non-lethal methods and devices. WS would not investigate wolf 

36 depredation complaints to determine if the wolves are responsible for losses. WDFW, USFWS, 

37 and tribes could take the same actions as those described under the No Action alternative, thus 

38 nonlethal and lethal control would still occur. The cumulative effects of such actions are similar 

39 to the current environment under which wolves exist, and are discussed as the environmental 

40 baseline, or the environmental status quo in Section 4.1.

41

42

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 51
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 4.2.1 Impact on wolf population 

2

3 Direct effect

4

5 WS would have no involvement or effect with/on wolves. 

6

7 Cumulative effects on gray wolves in Washington

8

9 The cumulative effects on wolves would be similar to that described under Section 4.1.1. 

10 USFWS has responsibility for managing federally listed wolves, WDFW has responsibility for 

11 managing federally delisted wolves, and tribal governments have authority on tribal lands within 

12 their boundary. Ranchers and livestock producers must work directly with WDFW and USFWS

13 when wolf/livestock conflicts occur in their areas of management. Livestock producers that see 

14 wolves on their property or suspect wolves have attacked livestock are instructed to immediately 

15 call WDFW, USFWS, or county officials. WDFW, USFWS, or tribes would implement wolf 

16 damage management per appropriate regulations, as discussed in Section 2.1, and individual 

17 wolves are expected to be removed when and where a need exists and in accord with the 

18 requirements for removal. In addition, producers in areas where wolves are managed by the state 

19 (currently within the NRMDPS boundary), and who have been issued a WDFW permit or catch 

20 wolves attacking their animals (WAC 232-36-05100B), may kill wolves. 

21

22 Because WDFW would implement the WCMPW with or without the assistance of WS

23 (Appendix A), effects on the wolf population would be similar to the No Action Alternative.

24

25 4.2.2 Impacts on non-target animals and human safety 

26

27 Non-target animals

28

29 WS would have no effect on non-target species or humans under this alternative. 

30

31 Human Safety

32

33 WS would have no effect on human safety under this alternative.

34

35 Cumulative effects in Washington

36

37 Lethal methods would be used by WDFW, its agents, or tribes in the absence of any assistance 

38 from WS, and thus would present no change in human safety risk from that of the current 

39 environmental baseline (the No Action alternative). 

40

41 In the unlikely event that wolves threatened human safety, WDFW, USFWS, and tribes could 

42 take actions as allowed under the WCMPW, ESA, CFR, or tribal guidance. 

43

44

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 52
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 4.2.3 Social and Aesthetic Perspectives 

2

3 Non-lethal actions are generally preferred by members of the public. However, members of the 

4 public who experience wolf threats to or losses of livestock, as well as some pet owners, feel that 

5 they have a right to protect their property, and may consider it unacceptable that their 

6 domesticated animals be subjected to harm by wolves by using non-lethal methods if they are not 

7 effective. People have bred the defensive capabilities out of many domestic animals and thus 

8 may feel that they have an obligation to protect them from being killed by predators. 

9 As discussed in Section 4.1.3, livestock producers, some rural residents, and hunters would be 

10 more likely to approve of the most effective methods that will reduce wolf damages, and some 

11 members of the public would prefer if wolves were removed from Washington. 

12

13 Because WDFW (Appendix A), USFWS, or tribes could take necessary action to lethally remove 

14 wolves under this alternative, ultimately, social perspectives would be expected to be similar to 

15 the No Action Alternative.

16

17 Humaneness

18

19 The effects of this alternative would be similar to the No Action alternative because of the role of 

20 WDFW in implementation of the WCMPW, which allows for nonlethal and lethal control. 

21

22 Impact of wolf removal on public aesthetic enjoyment

23

24 Under this alternative, WS would have no effect on the ability of the public to enjoy wolves 

25 since it would have no effect on individual wolves or the wolf population. However for the 

26 reasons discussed under the No Action alternative, WDFW, USFWS, or tribes could take any 

27 necessary lethal actions and wolves would be affected similar to the No Action alternative. 

28 Thus, the ability of the public to potentially enjoy wolves in their natural habitat would be the 

29 same as Alternative 1, No Action.

30

31 4.2.4 Effectiveness 

32

33 Eliminating all assistance from WS would necessitate WDFW, USFWS, or tribes to direct 

34 personnel away from proactive damage management and conservation and recovery efforts, 

35 which would likely negatively affect wolf conservation and recovery and may result in increased 

36 wolf depredation on livestock (Appendix A). 

37

38 4.3 Alternative 3 – Proposed Action: Expand the Current Wolf Assistance Program

39

40 The Proposed Action alternative is to assist livestock producers, tribes, WDFW, and USFWS

41 with an integrated approach of technical assistance, wolf damage identification, and nonlethal

42 and, with the exception of USFWS, lethal wolf damage management approaches under the 

43 WCMPW or similar guidance. WDFW, USFWS, and tribes would continue to implement 

44 aspects of relevant wolf management (e.g., recovery and conservation) and WS would cooperate 

45 to provide the assistance necessary to respond to wolf complaints and resolve depredation. This 

46 alternative is almost identical to the No Action alternative except that WS could respond to 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 53
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 WDFW or tribe requests to provide conservation trapping and lethal removal in accordance with 

2 the WCMPW or similar guidance and assist the USFWS with conservation trapping when 

3 requested and under ESA guidelines. Having WS assist WDFW or the tribes with lethal removal 

4 of wolves will allow the other agencies to focus their personnel towards conservation and 

5 recovery of wolves in Washington.

6

7 This alternative is an improvement over the No Action alternative with actions allowed under the 

8 WCMPW, and the environmental consequences are similar to those under Alternative 1, No 

9 Action, because WS would be involved with lethal and non-lethal wolf damage management, 

10 instead of only WDFW, USFWS, or tribal personnel. The environmental consequences would 

11 be fewer than Alternative 2 as well, because WDFW would not be required to redirect its 

12 personnel from conducting wolf conservation and recovery projects. This alternative is expected 

13 to have the greatest efficacy in reducing wolf damage while benefiting wolf conservation and 

14 recovery in WA.

15

16 4.3.1 Impact on wolf population 

17

18 Direct effect

19

20 Effects on the wolf population under this alternative could result in a similar or lower level of 

21 wolf removal as compared with Alternatives One and Two (Appendix A). Under this alternative, 

22 WS may respond to WDFW or tribal requests to remove individual problem wolves under the 

23 conditions of the WCMPW or similar guidance and assist USFWS with wolf conservation efforts 

24 under ESA guidelines. This alternative would allow WDFW, USFWS, and tribal personnel to 

25 focus their efforts on conservation and recovery of gray wolves in Washington. It would not 

26 result in more wolves removed since WDFW, USFWS, or tribes are responsible for determining 

27 the number of wolves to remove and would respond if WS could not (Appendix A). 

28

29 Cumulative effects on gray wolves in Washington

30

31 The cumulative effect on the gray wolf population in Washington would be similar or lower than 

32 Alternatives One and Two. WDFW is already implementing the WCMPW and would continue 

33 to respond to wolf damage complaints in the absence of WS assistance (Appendix A). Without 

34 WS assistance, WDFW may need to take more wolves to address wolf damage (Appendix A). 

35 Because WDFW or tribes must make the decision regarding individual wolf removals of wolves 

36 under their jurisdiction, and because WS would be bound to the measures discussed in the 

37 WCMPW (Wiles et al. 2011) or similar guidance, the discussion and findings under the No 

38 Action Alternative, in which WDFW, USFWS, and tribes would act if WS did not, is expected to

39 be similar.

40

41 Under this alternative, WS would provide assistance to WDFW or tribes with lethal and non42 lethal wolf damage management and USFWS with non-lethal management and lethal 

43 management under provisions of the ESA. By providing WDFW and tribes with lethal 

44 management assistance, WDFW and tribes would be able to focus their personnel towards 

45 programs to enhance wolf recovery and conservation. Therefore, when compared with the No 

46 Action (current program) and Eliminate the Wolf Assistance Program alternatives, the proposed 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 54
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 action alternative would result in the greatest overall potential for wolf conservation by allowing 

2 WDFW (Appendix A), USFWS, and tribes to focus their staff time on wolf conservation and 

3 recovery efforts.

4

5 Ultimately, based on WS assistance to USFWS, WDFW under the WCMPW, WDFW’s public 

6 education and outreach, and the cautious and conservative approach to reducing wolf 

7 depredation, wolves are expected to continue to expand in Washington and establish populations 

8 in suitable habitat. Based on habitat connectivity and an abundance of wolves in other regions of 

9 the NRMDPS, it is reasonable to expect that wolves will expand within the foreseeable future to 

10 meet state and federal delisting criteria in Washington.

11

12 The Colville Indian Tribe opened wolf hunting to its members through 28 February 2013 or until 

13 3 wolves are taken in each of the 3 assigned regions on the Colville Indian Reservation. This 

14 action was taken after communication with state authorities and done in order to control wolf 

15 populations that threaten the deer and elk tribal members rely on. WDFW takes tribal hunting 

16 into account when determining wolf recovery actions so that tribal hunting will not add adverse 

17 cumulative impacts to WDFW permitted wolf removals during wolf conservation and recovery 

18 processes. WDFW does not believe that this action will inhibit wolf recovery efforts in 

19 Washington (Pers. comm. Dave Ware, WDFW, July 2013).

20

21 Because Washington wolf conservation and management is a relatively new issue, WS has 

22 limited its proposed role in using lethal depredation management methods to the guidance under 

23 the WCMPW, ESA, or similar guidance from tribes.

24

25 4.3.2 Impacts on non-target animals and human safety 

26

27 Non-target animals

28

29 There would be little to no difference in the effect to non-target animals because WDFW, its 

30 agents, USFWS, WS, and tribes could use the same tools. Neck snares have potential to affect 

31 non-targets. The exposure of non-target animals to neck snares is mitigated through consultation 

32 with the USFWS under Section 7 of the ESA (Appendix C). Neck snares would primarily be 

33 used in the winter time when few non-target species are present, set in wolf trails leading 

34 to/away from depredation sites, and set to avoid capturing non-target animals. While there may 

35 be some risk to larger non-target animals such as bear and cougar, the level of use of lethal tools 

36 would be so low as to render negative effects on non-target species unlikely. WS may apply 

37 other techniques more proficiently than WDFW, so effects to non-targets could be somewhat less 

38 under this alternative. WS may use neck snares when foothold traps are less effective due to 

39 their mechanical nature. This tool is available to WDFW, and WS as its agent, under RCW 

40 77.15.010, so it may not result in a difference in removing depredating wolves to promote wolf 

41 recovery and conservation in WA.

42

43 WS Standard Operating Procedures to minimize the capture of non-target animals is discussed in 

44 Section 2.3.

45

46

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 55
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 Threatened and Endangered Species

2

3 During development of this EA, Wildlife Services reinitiated consultation with the USFWS

4 (February 1, 2013), pursuant to the federal Endangered Species Act, for potential program effects 

5 on bull trout (Salvelinus confluentus), Canada lynx (Lynx canadensis), Columbian white-tailed 

6 deer (Odocoileus virginianus leucurus), gray wolf (Canis lupus), grizzly bear (Ursus arctos 

7 horribilis), pygmy rabbit (Brachylagus idahoensis), and Pacific coast population of the western 

8 snowy plover (Charadrius nivosus nivosus). WS determined “no effect” for marbled murrelet 

9 (Brachyramphus marmoratus), northern spotted owl (Strix caurina occidentalis), short-tailed 

10 albatross (Phoebastria albatrus), and woodland caribou (Rangifer tarandus caribou). WS 

11 determined “may affect, not likely to adversely affect” for bull trout, Columbian white-tailed 

12 deer, and pygmy rabbit. WS’ final determination for western snowy plover, gray wolf, and 

13 grizzly bear was “may affect, likely to adversely affect”. Based on meetings and discussions 

14 with USFWS, we expect USFWS to concur with these determinations. Actions relative to this 

15 EA would have no impact on western snowy plover, may adversely affect individual federally 

16 listed grays wolves (though be beneficial to the long-term recovery of the species), and may

17 adversely affect grizzly bear if WS accidently captured a grizzly bear during wolf trapping 

18 actions. In order to ensure that WS actions would not jeopardize federally listed gray wolves or 

19 grizzly bear, WS would implement the conservation measures proposed in Section 2.3.

20

21 Human Safety

22

23 The methods proposed by WS would be the same as those used by WDFW under the No Action 

24 alternative. WS is unaware of any impacts to public health or safety associated with agency 

25 implementation of wolf damage management methods in other states. 

26

27 Aerial operations would likely occur in relatively remote areas with no or very low human 

28 presence on the ground. A formal risk assessment of methods used in wildlife damage 

29 management concluded there was very little, if any, risk to the public from WS aerial shooting 

30 activities (USDA 1997, Appendix P). Other analyses of aircraft accidents by WS concluded that 

31 the accident rate for WS pilots and aircraft is not significantly different from rates reported for 

32 general aviation and that the risk of harming any member of the public is exceedingly low 

33 (USDA 2011a, 2011b). We find no reason to believe that aerial operations used in wolf damage 

34 management would present any significant risk to public health or safety in Washington.

35

36 WS’ traps and snares are strategically placed to reduce the likelihood of exposure to the public. 

37 Appropriate warning signs are posted at access points to areas or properties where traps or snares 

38 are set to alert the public of their presence (WS Directive 2.450). In Idaho, where wolf removal 

39 efforts are relatively high compared to what is anticipated in Washington, there have been no 

40 injuries from WS wolf damage management activities reported to WS, USFWS, Idaho Fish and 

41 Game.

42

43 Humans are not likely to be exposed because of the remoteness or locations on private lands 

44 where wolf removals generally occur. WS’s use of traps and snares has not presented any safety 

45 risks to people (MIS 2012). This conclusion was made on the national WS program by a formal 

46 risk assessment of WS methods (USDA 1997, Appendix P). Similar to the No action alternative, 

47 this Alternative could provide relief from damage or threats to public health and safety for 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 56
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 people who would have no relief from such damage or threats if non-lethal methods were 

2 ineffective or impractical. 

3

4 4.3.3 Social and Aesthetic Perspectives 

5

6 Humaneness

7

8 People’s perspectives on wolf damage management and on the removal of wolves under the 

9 proposed action would be expected to be similar to the No Action and Non-lethal only 

10 alternatives since wolves would be removed in a similar manner and number, under the same 

11 criteria (Wiles et al. 2011), and for the same reasons. While WS may act as an agent to 

12 landowners holding lethal removal permits, additional take is unlikely for the reasons discussed 

13 under Section 4.3.1. 

14

15 With regard to the humane treatment of wolves, the proposed action would be similar to the 

16 other alternatives as far as lethal methods that WS would use (as discussed in Section 4.1.3). WS 

17 would continue to provide non-lethal technical assistance to all who request it. The overall 

18 humaneness of the wolf management program may be enhanced under the proposed action 

19 alternative because by assisting WDFW and tribes with lethal depredation response efforts, they 

20 can focus their personnel towards recovery and conservations actions. 

21

22 With regard to the perspective of livestock producers and others who feel that domestic animals 

23 should be protected from predation, this alternative would probably be considered more humane 

24 than the other alternatives because WS may be able to respond to WDFW, USFWS (under ESA 

25 guidelines), and tribal requests for lethal removal faster and more efficiently than their agents 

26 could. WS already has personnel in the field that have the expertise to identify and resolve 

27 wildlife damage. By expediting response times, the potential for continued or additional wolf 

28 depredation on livestock can be reduced. Enhancing agency depredation management efficiency 

29 is likely to promote social tolerance of wolves in Washington, as discussed under Section 4.1.3. 

30

31 Aesthetic effects

32

33 Some individuals contend that there is an “existence value” placed on wolves: that a value exists 

34 even though a large segment of the public will never actually see or hear a wolf. Because WS is 

35 not proposing to remove all wolves nor would WDFW authorize the killing of all wolves as a 

36 manner to recover and conserve the species in Washington, there will be wolves available to 

37 continue the concept of “existence value”. The ability to view and aesthetically enjoy wolves at 

38 a particular site could be temporarily limited when a wolf is removed. New animals would most 

39 likely reoccupy the site in the future if suitable habitat exists, although the length of time until 

40 new wolves arrive is variable, depending on the habitat type, time of year, and population density 

41 of wolves in nearby areas. While non-consumptive users could be temporarily affected by 

42 localized removals (especially if they recreated in areas where wolf/livestock conflicts were 

43 occurring), the overall effect would be beneficial in terms of the potential for people to 

44 aesthetically enjoy wolves in the wild in the long term. This alternative would provide the 

45 highest level of support towards wolf conservation and recovery in Washington as identified in 

46 the WMCPW (Wiles et al. 2011, Appendix A). Therefore, non-consumptive users would benefit 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 57
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 most from this alternative. Still, there are likely to be groups and individuals who would be 

2 opposed to any control of wolves, regardless of the long-term beneficial role it plays in the 

3 conservation of wolves.

4

5 The likelihood of getting to see wolves is probably very low currently due to the limited numbers 

6 of wolves in Washington, the remote areas they inhabit, and the lack of access to private lands 

7 where wolves often occur. The ability to directly enjoy wolves in the wild will probably be 

8 greatest for people who have knowledge of wolf behavior and habits and make the effort to visit 

9 sites with adequate habitat outside of damage management areas. 

10

11 4.3.4 Effectiveness 

12

13 The effectiveness of the tools and techniques proposed under this alternative to manage 

14 depredation would be similar to the No Action alternative since either way, non-lethal methods 

15 are in use when they are effective, and agency lethal control would take place using the same 

16 approach as provided by WCMPW. However, the proposed action would likely be more 

17 efficient in resolving depredation than the No Action and Eliminate the Wolf Assistance 

18 Program alternatives in alleviating additional livestock damages. WS may be more efficient in 

19 responding to agency or tribal orders to remove depredating wolves as prescribed and needed to 

20 prevent further losses because it has personnel in the field who already assist landowners with 

21 other wildlife damage conflicts. WS personnel may be more readily available to provide 

22 assistance sooner than if WDFW or tribes alone implemented lethal measures on depredating 

23 wolves. As WDFW stated on 11 January 2013, in a letter to WS (Appendix A), 

24

25 We anticipate continued rapid growth of Washington’s wolf population and 

26 without your help, we will not be able to adequately address or manage conflicts. 

27 If we are unable to adequately manage conflicts, public tolerance for wolves will 

28 decline and recovery efforts could be jeopardized. While WDFW would still 

29 provide necessary removals of wolves in the absence of additional WS assistance, 

30 WDFW will not be able to respond as efficiently to potential or actual 

31 depredation events and thus producers may suffer greater levels of damages. 

32 Additionally, without your program’s expert assistance, WDFW would probably 

33 need to redirect personnel from overall conservation and recovery to focus on 

34 responding to damages. For these reasons, without the assistance of your 

35 program, overall conservation and recover y may be hampered.

36

37 The same number or fewer wolves may be removed under this alternative (Appendix A), and

38 targeting and capture of depredating wolves would be expedited under the proposed action. 

39 Because repeatedly depredating wolves may continue depredating on livestock, fewer livestock 

40 losses would probably occur under this alternative. Removing a depredating wolf early may also 

41 result in fewer pack members learning to depredate livestock, thereby reducing future 

42 depredations further.

43

44

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 58
CHAPTER 4. ENVIRONMENTAL CONSEQUENCES

1 4.4 Summary and Conclusions 

2

3 This EA discusses approaches that WS could take to respond to requests from WDFW, USFWS, 

4 and tribes to assist with implementing portions of the WCMPW (Wiles et al. 2011) or similar 

5 guidance. The essential decision presented to WS, is not how to manage wolf damage to 

6 livestock, but whether or not to assist the WDFW, USFWS, and tribes with specific actions 

7 dictated by the WCMPW or similar guidance. This EA also evaluates the current non-lethal only 

8 alternative (No Action). The analysis in the EA shows that results of the No Action and 

9 Eliminate the Wolf Assistance Program alternatives would be similar to the proposed action 

10 because WDFW and tribes would continue to take necessary actions to remove repeatedly 

11 depredating/problem wolves if WS did not. The primary differences between the alternatives are 

12 the probable increased efficacy of the proposed action in reducing livestock damage and 

13 enhancing the ability of WDFW and the USFWS to conserve wolves to the point of recovery, as 

14 compared with the No Action and Eliminate the Wolf Assistance Program alternatives. WS has 

15 no decision authority over WDFW, USFWS, or tribes in regards to calling for the removal of

16 problem wolves. The decision to be made is to respond or not respond to their requests directing 

17 when, where, and which wolves should be removed. The methods used to capture wolves 

18 include the same methods described in Chapter 2 which WS would use in providing requested 

19 assistance. The WCMPW is very specific about the criteria which call for any lethal effects on 

20 wolves and if WS were to participate, it would be following such direction by WDFW or similar 

21 direction from USFWS (under ESA guidelines) or tribes (under their sovereign tribal authority). 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 59
CHAPTER 5. LITERATURE CITED

CHAPTER 5 – Literature Cited

Andelt, W. F. 1987. Coyote predation. (Pages 128-140) in M. Nowack, J. A Baker, M. E. 

Obbard, and B. Malloch, editors. Wild furbearer management and conservation in North 

America. Ontario Trappers Association North Bay, Ontario, Canada.

AVMA. 2013. AVMA guidelines for the euthanasia of animals: 2013 edition. American 

Veterinary Medical Association, Schamburg, Illinois, USA.

Bangs, E. E., and J. Shivik. 2001. Managing wolf conflict with livestock in the Northwestern 

United States. Carnivore Damage Prevention News 3: 2-5. 

Bangs, E. E., S. H. Fritts, J. A. Fontaine, D. W. Smith, K. M. Murphy, C. M. Mack, and C. C. 

Niemeyer. 1998. Status of gray wolf restoration in Montana, Idaho, and Wyoming. 

Wildlife Society Bulletin 26: 785-798. 

Bangs, E., M. Jimenez, C. Niemeyer, T. Meier, V. Asher, J. Fontaine, M. Collinge, L. 

Handegard, R. Krischke, D. Smith, and C. Mack. 2005. Livestock guarding dogs and 

wolves in the Northern Rocky Mountains of the United States. Carnivore Damage 

Prevention News 8: 32-39.

Bangs, E. E., M. Jimenez, C. Niemeyer, J. Fontaine, M. Collinge, R. Krischke, L. Handegard, J.

Shivik, C. Sime, S. Nadeau, C. Mack, D. Smith, V. Asher, and S. Stone. 2006. Non-lethal

and lethal tools to manage wolf-livestock conflict in the northwestern United States. 

Proceedings of the Vertebrate Pest Conference 22: 7-16.

Bangs, E., M. Jimenez, C. Niemeyer, J. Fontaine, C. Sime, S. Nadeau, and C. Mack. 2009. The 

art of wolf restoration in the northwestern United States: Where do we go now? (Pages 95-

114) in M. Musiano, L. Boitani, and P. Paquet, editors. A new era for wolves and people: 

wolf recovery, human attitudes, and policy. University of Calgary Press. Alberta, Canada.

Bishop, R. C. 1987. Economic values defined. (Pages 24-33) in D. J. Decker and G. R. Goff, 

editors. Valuing wildlife: economic and social perspectives. Westview Press, Boulder, 

Colorado, USA.

Bjorge, R. R., and J. R. Gunson. 1985. Evaluation of wolf control to reduce cattle predation in 

Alberta. Journal of Range Management 38: 483-487. 

Boitani, L. 2003. Wolf conservation and recovery. (Pages 317-340) in L. D. Mech and L. 

Boitani, editors. Wolves: behavior, ecology, and conservation. The University of Chicago 

Press, Chicago, USA and London, England.

Bradley, E. H. 2004. An evaluation of wolf-livestock conflicts and management in the 

northwestern United States. Thesis, University of Montana, Missoula, USA.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 60
CHAPTER 5. LITERATURE CITED

Bradley, E. H., and D. H. Pletscher. 2005. Assessing factors related to wolf depredation of 

cattle in fenced pastures in Montana and Idaho. Wildlife Society Bulletin 33: 1256-1265.

Brainerd, S. M., H. Andre ́n, E. E. Bangs, E. Bradley, J. A. Fontaine, W. Hall, Y. Iliopulos, M. 

D. Jimenez, E. A. Jozwiak, O. Liberg, C. M. Mack, T. J. Meier, C. C. Niemeyer, H. C. 

Pedersen, H. K. Sand, R. N. Schultz, D. W. Smith, P. Wabakken, and A. P. Wydeven. 2008. 

The effects of breeder loss on wolves. Journal of Wildlife Management 72: 89-98. 

Breck, S. W., R. Williamson, C. Niemeyer, and J. A. Shivik. 2002. Non-lethal radio activated 

guard for deterring wolf predation in Idaho: summary and call for research. Proceedings of 

the Vertebrate Pest Conference 20: 223-226. 

Bureau of Land Management (BLM). 2004. EMS TRANSMISSION Instruction Memorandum 

No. 2004-140 Revisions and Clarifications to H-8550-1, Interim Management Policy for 

Lands Under Wilderness Review, as it Relates to Wildlife Management.

Cain, S., A. Kadlec, D. L. Allen, R. A. Cooley, M. C. Hornocker, A. S. Leopold, and F. H. 

Wagner. 1972. Predator control - 1971 report to the council on environmental quality and 

the department of the interior by the advisory committee on predator control. Council on 

Environmental Quality and United States Department of the Interior, Washington, DC, 

USA.

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

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

Cochrane, J. F., R. G. Haight, and A. M. Starfield. 2003. Modeling for endangered-species 

recovery: gray wolves in the Western Great Lakes Region. in Dale, Virginia H., editor. 

Ecological Modeling for Resource Management. New York, NY: Springer-Verlag: 23-45 

<http://www.ncrs.fs.fed.us/pubs/book/nc_2003_cochrane_001.pdf>

Coppinger, R., and L. Coppinger. 1996. Interactions between livestock guarding dogs and 

wolves. (Pages 523-526) in L. N. Carbyn, S. H. Fritts, D. R. Seip, editors. Ecology and 

conservation of wolves in a changing world. Canadian Circumpolar Institute, Occasional 

Publication No. 35, 642 pp.

Davidson-Nelson, S. J., and T. M. Gehring. 2010. Testing fladry as a non-lethal management 

tool for wolves and coyotes in Michigan. Human-Wildlife Interactions 4: 87-94. 

Decker, D. J., and G. R. Goff. 1987. Valuing wildlife: Economic and social perspectives. 

Westview Press. Boulder, USA.

Dorrance, M. J., and J. Bourne. 1980. An evaluation of anti-coyote electric fencing. Journal of 

Range Management 33: 385-387. 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 61
CHAPTER 5. LITERATURE CITED

Fritts. S. H., W. J. Paul, and L. D. Mech. 1984. Movements of translocated wolves in 

Minnesota. Journal of Wildlife Management 48: 709-721. 

Fritts, S. H., W. J. Paul, and L. D. Mech. 1985. Can relocated wolves survive? Wildlife Society 

Bulletin 13: 459-463. 

Fritts, S. H., W. J. Paul, L. D. Mech, and D. P. Scott. 1992. Trends and management of wolf 

livestock conflicts in Minnesota. Resource Publication 181. United States Fish and Wildlife 

Service, Washington D.C., USA.

Fuller, T. K., L. D. Mech, and J. F. Cochrane. 2003. Wolf population dynamics. (Pages 161-

191) in L. D. Mech and L. Boitani, editors. Wolves: behavior, ecology, and conservation. 

University of Chicago Press, Chicago, USA.

Gustavson, C. R., and L.K. Nicolaus. 1987. Taste aversion conditioning in wolves, coyotes, and 

other canids: retrospect and prospect. (Pages 169-203) in H. Frank, editor. Man and wolf: 

advances, issues, and problems in captive wolf research. W. Junk, Boston, Massachusetts, 

USA.

Haight, R. G., L. E. Travis, K. Nimerfro, and L.D. Mech. 2002. Computer simulation of wolf 

removal strategies for animal damage control. Wildlife Society Bulletin 30: 844-852.

Howery, L. D. and T. J. DeLiberto. 2004. Indirect effects of carnivores on livestock foraging 

behavior and production. Sheep and Goat Research Journal Volume 19. 

<http://www.sheepusa.org/index.phtml? 

page=site/news_details&nav_id=30836f603c6643459e70ae92e558dd7e&nav_parent_id=60

1e0a31bbf6a0ef56f1f0591aa0dc78&volume=Volume%2019,%202004%20-

Special%20Edition:%20Predation>

IDFG. 2008. Idaho Wolf Population Management Plan 2008-2012. Idaho Department of Fish 

and Game, Boise, USA. 

<http://fishandgame.idaho.gov/cms/wildlife/wolves/manage/PopManagePlan.pdf>

Idaho Department of Fish and Game and Nez Perce Tribe. 2012. 2011 Idaho wolf monitoring 

progress report. Idaho Department of Fish and Game, 600 South Walnut, Boise, Idaho; Nez 

Perce Tribe Wolf Recovery Project, P.O. Box 365, Lapwai, Idaho. 94 pp.

Julien, T. J., S. M. Vantassel, S. R. Groepper, and S. E. Hyngstrom. 2010. Euthanasia methods 

in field settings for wildlife damage management. Human-Wildlife Interactions 42: 158-

164. 

Karlsson, J. and O. Johansson. 2009. Predictability of repeated carnivore attacks on livestock 

favours reactive use of mitigation measures. Journal of Applied Ecology 47: 166-171.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 62
CHAPTER 5. LITERATURE CITED

Keith, L. B. 1983. Population dynamics of wolves. (Pages 66-77) in L. N. Carbyn, editor. 

Wolves in Canada and Alaska: their status, biology, and management. Canadian Wildlife 

Service Report Series 45, Ottawa, Canada.

Kluever, B. M., S. W. Breck, L. D. Howery, P. R. Krausman, and D. L. Bergman. 2008. 

Vigilance in cattle: the influence of predation, social interactions and environmental factors. 

Rangeland Ecology and Management 61: 321-328.

Lehmkuhler, J., G. Palmquist, D. Ruid, R. Willging, and A. Wydeven. 2007. Effects of wolves 

and other predators on farms in Wisconsin: beyond verified losses. Pub-ER-658 2007, 

Wisconsin Department of Natural Resources, Madison, USA. http://dnr.wi.gov/org/land/er/ 

publications/pdfs/wolf_impact.pdf 

Linhart, S. B. 1984. Managing coyote damage problems with non-lethal techniques: recent 

advancements in research. Proceedings of the Eastern Wildlife Damage Control Conference 

1: 105-118.

Mack, J. A., W. G. Brewster, and S. H. Fritts. 1992. A review of wolf depredation on livestock 

and implications for the Yellowstone area. (Pages 3-20) in J. D. Varley and W G. Brewster, 

editors. Wolves for Yellowstone? A report to the United States Congress. Volume IV 

Research and Analysis. National Park Service, Yellowstone National Park, Mammoth Hot 

Springs, Wyoming, USA.

Mech, L. D. 1995. The challenge and opportunity of recovering wolf populations. 

Conservation Biology 9: 270-278.

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

Bulletin 29: 70-77.

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

143-149.

Mech, L. D., and L. Boitani. 2003. Wolf social ecology. (Pages 1–34) in L. D. Mech and L. 

Boitani, editors. Wolves: behavior, ecology and conservation. University of Chicago Press, 

Chicago, Illinois, USA. 

Mech, L. D., S. H. Fritts, and M. E. Nelson. 1996. Wolf management in the 21st century: from 

public input to sterilization. Journal of Wildlife Research 1: 195-198. 

<http://www.npwrc.usgs.gov/resource/mammals/wolfman/index.htm (Version 

02MAR2000).>

Mech, L. D., E. K. Harper, T. J. Meier, and W. J. Paul. 2000. Assessing factors that may 

predispose Minnesota farms to wolf depredations on cattle. Wildlife Society Bulletin 28: 

630-635.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 63
CHAPTER 5. LITERATURE CITED

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

NW, Olympia, WA 98502. 

Muhly, T. B., and M. Musiani. 2009. Livestock depredation by wolves and the ranching 

economy in the Northwestern U. S. Journal of Ecological Economics 10: 1016.

Muhly, T. B., M. Alexander, M. S. Boyce, R. Creasey, M. Hebblewhite, D. Paton, J. A. Pitt, and 

M. Musiani. 2010. Differential risk effects of wolves on wild versus domestic prey have 

consequences for conservation. Oikos 119: 1243-1254. 

Musiani, M., C. Mamo, L. Boitani, C. Callaghan, C. Cormack Gates, L. Mattei, E. Visalberghi, 

S. Breck, and G. Volpi. 2003. Wolf depredation trends and the use of fladry barriers to 

protect livestock in western North America. Conservation Biology 17: 1538-1547. 

Nass, R. D., and J. Theade. 1988. Electric fences for reducing sheep losses top predators. 

Journal of Range Management 412: 251-252.

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

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

Vertebrate Pest Conference 16: 57-60.

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

and movements in central Idaho. Journal of Wildlife Management 67: 299-306. 

Olson, J. F., and R. Tischaefer. 2004. Cable restraints in Wisconsin: a guide to responsible use. 

Wisconsin Department of Natural Resources, Madison, USA and Wisconsin Trappers 

Association.

Oregon Department of Fish and Wildlife (ODFW) 2010. Oregon Wolf Conservation and 

Management Plan, 2005 and Updated 2010. Oregon Department of Fish and Wildlife. 

http://www.dfw.state.or.us/Wolves/docs/Oregon_Wolf_Conservation_and_Management_Pl

an_2010.pdf

Oregon Department of Fish and Wildlife (ODFW). 2012. Oregon depredation list for WS. A 

report provided to WS by Russ Morgan, Wolf Coordinator, ODFW, La Grande, 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 dogtraining shock collars to deter depredation by gray wolves. Wildlife Society Bulletin 33: 

142-148.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 64
CHAPTER 5. LITERATURE CITED

Shelton, M. 2004. Predation and Livestock Production – Perspective and Overview. Sheep and 

Goat Research Journal Volume 19. <http://www.sheepusa.org/index.phtml?page=site/ 

news_details&nav_id=4e92bbbcf5184ed243442d8fa0a7c677&nav_parent_id=601e0a31bbf

6a0ef56f1f0591aa0dc78&volume=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 disruptive stimulus applications for 

managing predation. Proceedings of the Wildlife 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: 1531-1538. 

Slate, D. A., R. Owens, G. Connely, and G. Simmons. 1992. Decision making for wildlife 

damage management. Transactions of the North American Wildlife and Natural Resource 

Conference 57: 51-62.

Smith, R. H., D. J. Neff, and N. G. Woolsey. 1986. Pronghorn response to coyote control - a 

benefit: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: 231-241.

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 

Depredating Wolves in Michigan. United States Department of Agriculture, Animal and 

Plant Health Inspection Service, Wildlife Services, Okemos, Michigan, USA.

USDA, 2008. Final Environmental Assessment for the Management of Wolf Conflicts and 

Depredating Wolves in Wisconsin. United States Department of Agriculture, Animal and 

Plant Health Inspection Service, Wildlife Services, Sun Prairie, Wisconsin, USA.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 65
CHAPTER 5. LITERATURE CITED

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 Damage Management in Idaho for 

Protection of Livestock and other Domestic Animals, Wild Ungulates, and Human Safety. 

USDA APHIS-WS, Boise, Idaho.

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

USDA APHIS WS, Reno, Nevada.

USFWS. 1994. The reintroduction of gray wolves to Yellowstone National Park and central 

Idaho: Final environmental impact statement. U.S. Fish and Wildlife Service, Denver, 

Colorado, USA.

USFWS. 2003. Notice of Remanded Determination of Status for the Contiguous United States 

Distinct Population Segment of Canada Lynx. Federal Register. 68:40076. 

USFWS. 2008. Environmental Assessment and Finding of No Significant Impact for Proposed 

Revision Of Special Regulation for the Reintroduction of Gray Wolves Into the Central 

Idaho and Yellowstone Areas. U.S. Fish and Wildlife Service, Washington D.C., USA. 

<http://www.fws.gov/mountainprairie/species/mammals/wolf/EA_01182008/Wolf_10j_FONSI_EA_011608.pdf >

USFWS. 2009. Wyoming gray wolf recovery status report for the week of May 11-15, 2009. 

U.S. Fish and Wildlife Service, Washington D.C., USA. <http://www.fws.gov/mountainprairie/species/mammals/wolf/wyomingStatus09/05152009.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 Wildlife, Olympia, Washington. 215 pp.

Wiles, G. J., H. L. Allen, and G. E. Hayes. 2011. Wolf conservation and management plan for 

Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 297 pp.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 66
CHAPTER 5. LITERATURE CITED

Appendix A: WDFW Letter

RECEIVED

JAN 14 ·2013-=

State of Washington

Department of Fish and Wildlife

BY:

Mailing Address: 600 Capitol Way N, Olympia,WA 98501-1091,(360) 902-2200,TDD (360) 902-2207

Main Office Location:Natural Resources Building,1111 Washington Street SE, Olympia,WA

January 11, 2013

Roger Woodruff

State Director

Wildlife Services for Washington and Alaska

USDA Anima l and Plant Health Inspection Service

720 O'Leary Street Northwest

Olympia, Washington 98502

Dear Mr. Woodruff:

Thank you for your recent letter and follow up questions requesting information and clarification 

regarding the Washington Department of Fish and Wildlife's (WDFW) implementation of 

Washington's Wolf Conservation and Management Plan (Plan). The Plan was adopted by the 

Washington Fish and Wildlife Commission in December 2011 and implementation began

immediately. WDFW has been somewhat surprised by how quickly Washington's wolf population

has increased and the level of conflicts experienced over the past several months.

We are requesting the assistance of Wildlife Services (WS) in helping us address wolf conflicts and

in capture and monitoring efforts for management and research as part of implementing the Plan. 

We request WS's participation in these activities anywhere in the state where WDFW is the lead. 

We also ask that WS assist us were the U.S. Fish and Wildlife Service has management authority

through the Endangered Species Act, but has authorized WDFW to take management actions.

WDFW has been trapping, capturing, and monitoring wolves since 2008, and we currently have 

eight confirmed packs and four suspected packs being monitored by the Department and/or 

cooperating tribes. Wolves were killed by WDFW this year for the first time in response to 

chronic depredation of livestock. Our efforts to kill wolves included trapping and shooting, both 

from the ground and with the aid of a helicopter. These lethal removal efforts will continue by

WDFW regardless of whether WS is able to assist us. WDFW is authorized and plans to implement 

a variety of wolf-livestock management measures including: preventative advice, deterrents,

harassment, and lethal removal in cases of chronic depredation. Lethal removal authority for

WDFW includes using foothold traps, shooting (including aerial techniques), and snares.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 67
APPENDIX A

Roger Woodruff

January 11, 201 3

Page 2

We are requesting WS assistance with wolf-livestock conflict management because we do not 

have the capacity to adequately address the level of conflict we have already experienced. We 

anticipate continued rapid growth of Washington’s wolf population and without your help,

we will not be able to adequately address or manage conflicts. If we are unable to adequately

manage conflicts, public tolerance for wolves will decline and recovery efforts could be

jeopardized. While WDFW would still provide necessary removals of wolves in the absence

of additional WS assistance, WDFW will not be able to respond as efficiently to potential or

actual depredation events and thus producers may suffer greater levels of damages. 

Additionally, without your program’s expert assistance, WDFW would probably need to

redirect personnel from overall conservation and recovery to focus on responding to damages. 

For these reasons, without the assistance of your program, overall conservation and recover y

may be hampered.

One of the lessons we learned this year is the need to anticipate conflicts rather than just

respond to reported depredations. We want to be working with livestock producers proactively

next spring and using techniques to minimize conflicts rather than responding to escalating

depredation events. This proactive approach should help us minimize the number of lethal

removals necessary and hopefully completely avoid the need for the removal of an entire pack.

WDFW staffing levels and resources are not adequate for such a comprehensive proactive

approach, even at current wolf population levels. This shortfall will become even worse with the 

anticipated growth of Washington’s wolf population during the coming year.

We are look forward to working with WS in completing the environmental assessment and

in implementing Washington’s Wolf Conservation and Management Plan. We feel these are 

important steps for recovery of sustainable wolf populations in this state.

Sincerely,

Nate Pamplin, Assistant Director

Wildlife Program

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 68
APPENDIX B

Appendix B: 2011 MOU between WS and USFS

MEMORANDUM OF

UNDERSTANDING Between

USDA ANIMAL AND PLANT HEALTH INSPECTION SERVICE-WILDIFE

SERVICES

And The

USDA, FOREST SERVICE

NATIONAL FOREST SYSTEM

This MEMORANDUM OF UNDERSTANDING is hereby made and entered into by and

between USDA, Animal and Plant Health Inspection Service-Wildlife Services, hereinafter

referred to as·“APHIS-WS”,·and the USDA. Forest Service, National Forest System,

hereinafter referred to as the “U.S. Forest Service."

Background: The APHIS-WS and the Forest Service are agencies of the United States

Department of Agriculture (USDA) concerned with wildlife damage management

(WDM) and research on National Forest System (NFS) lands.

For the purposes of this agreement, WDM refers to actions initiated by APHIS-WS to

manage indigenous and feral vertebrates causing resource damage on NFS lands, to

minimize livestock losses due to predation by coyotes, mountain lions and other

predators, to manage wildlife diseases, to manage invasive species like feral hogs, and to

protect other wildlife, plants, and habitat from damage as requested by the Forest Service

and/or State or Federal wildlife management agencies. Under the Multiple Use

Sustained-Yield Act of 1960 (16 U.S.C. 528-532) and other authorities, the Forest

Service conducts activities to control wildlife damage to NFS resources caused by small

mammals and other animals, such as damage to timber stands by beavers. Occasionally,

WDM actions may be taken on NFS lands to protect resources on adjacent federal, tribal,

or non-federal land.

Title: WILDLIFE DAMAGE MANAGEMENT ACTIVITIES ON NATIONAL

FOREST SYSTEM LANDS

I. PURPOSE:

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

to identify responsibilities of the Parties and foster a partnership in discharging the

Federal obligation under the Act of March 2, 1931 (46 Stat. 1468:7 U.S.C. 426-426b),

as amended, the Act of December 22, 1987 (101 Stat. 1329-331. 7 U.S.C. 426c)

Executive Order 13112, and the 2008-2012 National Invasive Species Management 

Plan for the management of indigenous and invasive vertebrates causing damage on

NFS land; (2) to establish general guidelines to assist field personnel in carrying out

their WDM responsibilities consistent with policies of the Forest Service and APHISWS; and (3) to strengthen the cooperative approach to WDM on NFS lands through 

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 69
APPENDIX B

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, permittees, and

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

other areas where mitigation or restriction of WDM activities may be needed to

comply with forest plans.

C. Be responsible for NEPA compliance for wildlife damage, invasive and wildlife

disease management activities initiated by APHIS-WS and other WDM activities

as agreed upon by APHIS-WS on NFS lands and to coordinate with the FS and

appropriate State and local agencies and tribes in completing the NEPA process for

such activities. The FS will be responsible for NEPA compliance for any WDM

activities not covered above.

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

activities.

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

by APHIS-WS in a timelymanner. Additionally, provide the U.S. Forest Service

with an annual report, by State, summarizing the results of all WDM on NFS

lands. The annual report shall list the names and amounts of pesticides used.

F. Provide the U.S. Forest Service with technical information on WDM tools and

techniques. 

G. Conduct WDM training sessions for U.S. Forest Service personnel.

III. THE FOREST SERVICE SHALL:

A. Cooperate with APHIS-WS in the development and timely review of annual

WDM plans governing APHIS-WS activities, including pesticide-use proposals.

B. Participate in APHIS-WS NEPA processes as appropriate. The U.S. Forest Service will

be responsible for NEPA compliance on activities as defined in Section IV. A. below.

C. Invite APHIS-WS participation in all applicable U.S. Forest Service training at the

national, regional, and forest levels, especially NEPA and Wilderness training.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 70
APPENDIX B

D. Involve APHIS-WS in the amendment/revision of forest plans which may have an

impact on WDM activities.

IV. IT IS MUTUALLY AGREED AND UNDERSTOOD BY AND BETWEEN THE 

PARTIES THAT:

A. The U.S. Forest Service is responsible for managing land and resources under its

jurisdiction, including conducting certain routine WDM operations to protect NFS

lands and resources, and for assuring NEPA compliance for WDM activities requested

or initiated by the U.S. Forest Service.

B. APHIS-WS has been granted the authority and expertise under the Act of March 2,

1931 (46 Stat. 1468; 7 U.S.C. 426–426b), as amended, and the Act of December 22, 

1987 (101 Stat. 1329-331, 7 U.S.C. 426c) to provide WDM services. This includes

maintaining technical expertise in the science of WDMcontrol tools and techniques,

conducting WDM research, conducting management programs, conducting wildlife

disease surveillance, and complying with NEPA requirements for WDM.

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

Federal agencies prior to implementation of these programs.

D. WDM on NFS lands will be carried out in conformance with the Endangered Species

Act, Wilderness Act and other applicable laws and regulations, USDA policy on fish

and wildlife Departmental Regulation 9500-4), U.S. Forest Service policies, and

applicable forest land and resource management plans.

E. Parties will comply with all applicable Federal,State, and local laws and regulations 

in the use and application of pesticides.

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

and Federal agencies.

G. Both parties will ensure interagency coordination in analyzing the effects of WDM

activities by APHIS-WS on NFS lands and resources before NEPA decisions are

signed. The agency responsible for implementation of a specific project will also be

responsible for completion of NEPA analysis and documentation.

H. The WDM Programs will be evaluated on an annual basis, with emphasis on their

effectiveness in reducing damage or the threat of damage by wildlife and meeting the

objectives stated in this agreement and APHIS-WS relevant NEPA documents.

I. The APHIS-WS Deputy Administrator and the U.S. Forest Service Deputy Chief for

National Forest System (or their designees) will meet annually to discuss coordination of

WDM operations nationwide. APHIS-WS Regional Directors and U.S. Forest Service

Regional Foresters (or their designees) will meet annually, or as needed to discuss

coordination of WDM operations in their respective States or regions.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 71
APPENDIX B

J. Problemsregarding implementation of this agreement that arise and cannot be resolved

at the field level will be reviewed and resolved by elevating to the next higher

organizational level for prompt action. In the event of any issue of controversy under

the Agreement, the Parties may pursue Alternate Dispute Resolution procedures to

voluntarily resolve those issues. These procedures may include, but are not limited to,

conciliation,facilitation, mediation, and fact-finding.

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

L. The partiesshall manage their respective resources and activities in a separate,

coordinated, and mutually beneficial manner to meet the purposes of this agreement. 

Nothing in this agreement authorizes any of the parties to obligate or transfer funds.

Specific projects or activities that involve the transfer of funds, services, or property

among the partiesrequire execution of separate agreements and are contingent upon the

availability of appropriated funds. Each party operates under its own laws, regulations, and

policies, subject to the availability of appropriated funds.

M. PRINCIPAL CONTACTS. Individuals listed below are authorized to act in their

respective areas tor matters related to this instrument.

Principal Cooperator Contacts:

Cooperator Program Contact Cooperator Administrative Contact

Name: Deputy Administrator. Bill Clay

Address: USDA Animal & Plant Health 

Inspection Service. Wildlife Services,

Mail Stop 3402

City, State, Zip: Washington, DC 20250-3402

Telephone: (202) 720-2054

FAX: (202) 690-0053

Email: bill.clay@aphis.usda.gov

Name: Joanne Garrett

Address: USDA Animal & Plant Health

Inspection Service. Wildlife Services, 4700

River Rd., Unit 87. Room 2026

City. State. Zip: Riverdale. MD 20737-1234

Telephone: (301) 734-7921

FAX: (301) 734-5157

Email: joanne.p.garrett@aphis.usda.gov

Principal U.S. Forest Service Contacts:

U.S.Forest Service Program Contact U.S.Forest Service Administrative Contact

Name: Anne Zimmermann

Address: USDA Forest Service, Watershed, 

Fish, Wildlife, Air, and Rare Plants, 1400

Independence Ave., SW. Stop Code 1121

City, State. Zip: Washington, DC 20250-1121

Telephone: (202) 205-1167

FAX: (202) 205-1599

Email: azimmermann@fs.fed.us

Name: Felicia Lockhart

Address: USDA Forest Service, Watershed, 

Fish. Wildlife, Air, and Rare Plants. 1400

Independence Ave., SW, Stop Code 1121

City. State, Zip: Washington, DC 20250-1121

Telephone: (202) 205-1197

F :(202)205-1599

Email: flockhart@fs.fed.us

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 72
APPENDIX B

N. USE OF U.S. FOREST SERVICE INSIGNIA. In order for APHIS-WS to use

the U.S. Forest Service Insignia on any published media, such as a Web page,

printed publication, or audiovisual production, permission must be granted from

the U.S. Forest Service’s Office of Communications. A written request must he

submitted and approval granted in writing by the Office of Communications

prior to use of the insignia.

0. U.S. FOREST SERVICE ACKNOWLEDGED IN PUBLICATION,

AUDIOVISUALS, AND ELECTRONIC MEDIA. APHIS-WS shall acknowledge 

U.S. Forest Service support in any publications, audiovisuals, and electronic media

developed as a result of this instrument.

P. NONDISCRIMINATION STATEMENT-PRINTED, ELECTRONIC,OR

AUDIOVISUAL MATERIAL. APHIS-WS shall include the following statement, in

full, in any printed, audiovisual material, or electronic media for public distribution

developed or printed with any Federal funding.

"In accordance with Federal law and U.S. Department of

Agriculture policy, this Institution is prohibited from

discriminating on the basis of race, color, national origin, sex, age,

or disability. (Not all prohibited bases apply to all programs.)

To file a complaint of discrimination, write USDA. Director, Office of Civil

Rights, Room 326-W, Whitten Building, 1400 Independence Avenue, SW,

Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). 

USDA is an equal opportunity provider and employer."

If the material is too small to permit the fullstatement to be included, the material

must, at minimum, include the following statement, in printsize no smaller than the

text:

''This institution is an equal opportunity provider.''

Q. TERMINATION. Any of the parties, in writing, may terminate this MOU in whole,

or in part, at any time before the date of expiration.

R. NONBINDING AGREEMENT. This MOU creates no right, benefit, or trust

responsibility, substantive or procedural, enforceable at law or equity. The partiesshall

manage their respective resources and activities in a separate, coordinated and mutually

beneficial manner to meet the purpose(s)of this MOU. Nothing in this MOU authorizes

any of the parties to obligate or transfer anything of value.

Specific, prospective projects or activities that involve the transfer of funds,services, 

property, and/or anything of value to a party requires the execution of separate

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 73
APPENDIX B

instruments and are contingent upon numerous factors, including, as applicable, but

not limited to: agency availability of appropriated funds and other resources;

cooperator availability of funds and other resources; agency and cooperator

administrative and legal requirements (including agency authorization by statute): etc.

This MOU neither provides, nor meetsthese criteria. If the parties elect to enter into

an obligation instrument that involvesthe transfer of funds,services, property, and/or

anything of value to a party, then the applicable criteria must be met. Additionally,

under a prospective instrument, each party operates under its own laws, regulations.

And/or policies, and any Forest Service obligation issubject to the availability of 

appropriated funds and other resources. The negotiation, execution, and

administration of these prospective instruments must comply with all applicable law.

Nothing in this MOU is intended to alter, limit, or expand the agencies' statutory

and regulatory authority.

S. ALTERNATE DISPUTE RESOLUTION-INTERAGENCY. The parties to this

agreement shall settle any disputes that may arise under this agreement by following

direction in the Treasury Financial Manual, Volume 1, Bulletin 2007-03, Section VII

("Resolving lntragovernmental Disputes and Major Differences”).

T. MODIFICATIONS. Modifications within the scope of this instrument must be made

by mutual consent of the parties, by the issuance of a written modification signed and

dated by all properly authorized, signatory officials, prior to any changes being

performed. Requests for modification should be made, in writing, at least 30 days prior

to implementation of the requested change.

U. FREEDOM OF INFORMATION ACT (FOIA). Public access to agreement records

must not be limited, except when such records must be kept confidential and would 

have been exempted from disclosure pursuant to Freedom of Information regulations

(5 U.S.C. 552).

V. ENDORSEMENT. Any of APHIS-WS's contributions made under this agreement

do not by direct reference or implication convey U.S. Forest Service endorsement 

of APHIS-WS's products or activities.

W. NOTICES. Any notice given by the U.S. Forest Service or APHIS-WS will be

sufficient only if in writing and delivered in person, mailed, or transmitted

electronically by e-mail or fax, as follows:

To the U.S. Forest Service Program Manager, at the address specified in the grant.

To APHIS-WS, at the address shown in the grant or such other address

designated within the grant.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 74
APPENDIX B

X. PARTICIPATION IN SIMILAR ACTIVITIES. This agreement in no way restricts the

U.S. Forest Service or APHIS-WS from participating in similar activities with other

public or private agencies, organizations, and individuals.

Y. COMMENCEMENT/EXPIRATION DATE. This instrument is executed as of the

date of the last signature and is effective through April 15, 2016 at which time it will

expire, unless extended by an executed modification signed and dated by all properly

authorized, signatory officials.

Z. CONGRESSONAL RESTRICTION. Under 41 USC 22, no member of, or

delegate to, Congress shall be admitted to any share or part of the MOU or to

any benefit to arise therefrom.

AA. LIABILITIES. APHIS will hold the Cooperator harmless from any liability arising

from the negligent act or omission of the APHIS officer or employee acting within

the scope of his or her employment to the extent compensation is available pursuant

to the Federal Tort Claims Act (FTCA). 28 USC 2671 et. seq., except to the extent

that aforesaid liability arises from the negligent acts or omissions of the Cooperator, 

its employees, agents or subcontractor, and employees or agents of the

subcontractor(s). Such relief shall be provided pursuant to the procedures set for in

the FTCA and applicable regulations.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 75
APPENDIX B

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 76
APPENDIX C

Appendix C: Summary of Public Comments 

To be completed after public comments are received.

Pre-decision Environmental Assessment - Wildlife Services’ Gray Wolf Damage Management In Washington 77