February 16, 2006

From: Liz Sedler, Sandpoint, ID 83864
To: Idaho Fish and Game, PO Box 25, Boise, ID 83707

RE: IDFG Proposal to lethally remove wolves from the North Fork of the Clearwater and Lochsa drainages

Dear Sirs,

Please enter these comments, submitted on behalf of the Selkirk Conservation Alliance (“SCA”) and the Alliance for the Wild Rockies (“AWR”) into the record for this proposal. SCA and AWR are non-profit conservation organizations dedicated to maintaining and restoring habitat and populations of native wildlife and fish species. Restoration of wolves in Idaho and the Northern Rockies region is important to the members of SCA and AWR. These members would be negatively affected if IDFG’s proposal to remove approximately 75% of the wolves from the targeted area is implemented.

IDFG’s reliance on a draft report, “Effects of Wolf Predation on North Central Idaho Elk Populations” dated January 23, 2006 (“draft Report’) to justify the lethal removal of 43 wolves from the North Fork of the Clearwater and Lochsa drainages (GMUs 10, 12 and 17) fails to meet the requirements of the 10(j) Rule and is therefore in violation of the Endangered Species Act.

I. The draft Report fails to provide conclusive evidence that wolf predation is a significant factor in the decline of the elk herds in GMU’s 10, 12 and 17; it also fails to provide adequate data for the conclusion that the proposed reduction in the local wolf population will contribute significantly to the restoration of the elk population in the targeted area.

• The draft Report and other reliable sources indicate that elk numbers have historically been cyclical, rising and falling depending on available suitable habitat. Historic stand replacing fires played a huge role in increasing suitable elk habitat and subsequent increases in elk numbers. The Report acknowledges that due to fire suppression elk habitat has decreased substantially in the last 30-40 years, stating that “[h]abitat succession is a significant factor for declines in elk carrying capacity in the zone.” Draft Report at 20.
• The Report lacks long term range condition or trend studies for the Clearwater which are necessary to assess the relative availability of suitable elk habitat and potentially the major reason for declining populations.
• The data in the proposal indicate that wolf predation is not a significant factor in the recent decline in elk numbers. The Report states:
• In addition to loss of winter range brush fields and summer forage, the increasing age of brush fields promote habitat conditions that are favorable for ambush predators. Predators such as mountain lions and black bear that are primary predators of elk calves become much more effective if cover allows them to approach calves and cows unseen. Id.
• The proposal provides data indicating that bears and mountain lions are in large part responsible for the low survival rate of elk calves. Draft Report (Figure 14) at 45. According to the Report there currently is no evidence that wolves are a factor in low elk calf survival rates. Draft Report at 19.
• The draft report was reviewed by John G. Kie, Research Professor, Department of Biological Sciences, Idaho State University. His review, dated January 9, 2006, includes a comment on the low number of calf mortalities due to wolf predation: “It seems to me that whatever has been causing the decline in elk recruitment rates, it wasn’t wolf predation.”
• Furthermore, the data presented as the basis for wolf removal indicates that wolves may be a minor factor in the recent decline in elk numbers in the Lolo Zone. The draft Report states that 8 out of 25 known (collared) cow elk mortalities from 2002 – October 2005 in GMUs 10 and 12 were attributed to wolves. Of the eight 2 were in 2004 and 6 were in 2005 for an average of 2 cow elk deaths per year. This is the sole piece of hard evidence on which IDFG relies to arrive at the conclusion that 75% of the wolves that are known or suspected of inhabiting or visiting GMUs 10, 12 and 17 must be exterminated in order to increase elk numbers.
• The information in the proposal indicates that elk declines began in the winters of 1996 and 1997 prior to the return of wolves to the area in 2000. In response to elk declines following the winter of 1996-1997, citizens formed the Clearwater Basin Elk Habitat Initiative (CEI) in 1998 with federal, state, and private partners involved in elk and land management. Draft Report at 10.
• Dr. Kie’s comment: “These two previous statements indicate that 1) few wolves were present prior to 2000, and 2) elk declines were substantial enough as early as 1996-97 to institute the Clearwater Basin Elk Habitat Initiative (CEI). This strongly suggests that regardless of what effects wolves might be having on elk, there are strong indications that elk in these areas are being affected by changes in habitat conditions. These, in turn, are good arguments that elk numbers are being regulated in a density-dependent manner.”
• II. The predictive model is flawed.
  
  Dr. Kies also pointed out numerous problems with the assumptions and data used in the model formulated by IDFG to determine the impacts of wolf predation on elk populations. Excerpts from his comments:
• Draft Report Page 14: Implicit within the exponential model framework is the assumption that mortality, fecundity, and other parameters remain fixed despite changes in density. Over the narrow range of elk densities explored in our simulations, this assumption is reasonable.
• I believe it is difficult to argue for density independence, as stated in my previous comments above. In addition, it is not clear what the range of population densities were covered in your simulations. If the range was quite small, then model outcomes are of little value. It would be like trying to develop a regression equation or model over a narrow range of independent variables, and then applying the results to conditions outside those upon which the model was built. Finally, if one fixes mortality (mx) and fecundity (lx) rates in a simulation model like this, then resulting population size is fixed and the model becomes trivial.
• Draft Report Page 14: We assumed equal rates of fecundity and survival for all age classes of adult (≥2 yr) elk.
• This is not likely true. See Stewart et al. (2005:90), who documented maximum fecundity of female elk in northeastern Oregon at about 6 years of age, with lower rates among younger as well as older females. They also showed strong density-dependent effects on elk reproductive rates.
• Draft Report Page 14: Given their close proximity, the ecological similarities, and similar levels and patterns of elk population performance, we assume that most vital rates are similar across the 3 GMUs.
• Table 4 suggests quite different adult female survival rates in GMU 10(91% compared to GMU 12 (74%).
• Draft Report Page 14: Thus, adult cow survival was assumed to be 0.89 in GMU 12 and 0.932 in GMUs 10 and 17, in the absence of wolf predation.
• In GMU 10, actual female survival was 91% (Table 4), and estimated survival with no wolf predation at all was 93%, only a 2% increase? What is your estimate of adult female survival with your proposed control level? A legitimate question then is, why bother to control wolves in GMU 10?
• Draft Report Page 15: Several estimates were derived in the greater Yellowstone area, under varying conditions, revealing a range of 0.036 to 0.125 elk killed/wolf/day during winter (Jaffe 2001, Mech et al. 2001, Gude and Garrott 2003, Smith et al. 2004).
• Kill rates are far less important for establishing an equilibrium density of prey than is the relation of population density to carrying capacity, k, with the exception of prey at very, very low population densities (Marhsal and Boutin 1999, Person et al. 2001).
• Clearly the IDFG predictive model lacks scientific integrity. Therefore its results cannot be used as the basis for a decision to proceed with the proposal to dispose of the wolves.

III. Reliance on initial data from a ten year study is premature and lacks scientific integrity.

• The data presented in the draft report are the results of the first two years of a 10 year elk study. Decisions to reduce the wolf population should be based on substantially more data than is currently available. If IDFG desires the authority to “manage” wolves in Idaho, the agency must first recognize that that authority brings with it the responsibility to base decisions on incontrovertible evidence. It behooves IDFG to proceed cautiously and conservatively when making wolf management decisions. Such decisions must, by law, be based on the best available science, not on political pressure from anti-wolf contingents.

As pointed out in the IDFG draft Report, wildlife/predator management is extraordinarily complex and the risks involved in taking drastic measures in the hope of helping one species flourish may have unintended negative consequences on other species. Draft Report at 51. The cumulative effects of the proposed actions on wolf recovery, as well as long term viability of other native species must be assessed prior to proceeding with the current proposal.

The draft Report falls far short of providing an adequate biological basis to support the proposed wolf removal. The proposal appears to be a knee-jerk reaction to the diminishing of elk numbers in the targeted area and political pressure from anti-wolf constituents. The conclusion that wolf removal will result in an increase in elk is unsupported by the data.

Thank you for the opportunity to comment.

Regards,

Liz Sedler